Taxation

Thought Leaders

Alta Energy: Has the GAAR become toothless? – Part II

In part two of his two-part series, Allan Lanthier highlights areas of the Supreme Court's Alta Energy decision that are open to vigorous debate
Thought Leaders

Alta Energy: Has the GAAR become toothless? – Part I

In part one of a two-part series, Allan Lanthier looks at the details of the Alta Energy tax avoidance decision by the Supreme Court of Canada
Thought Leaders

The Canadian Taxpayers Federation’s politics are anti-Indigenous — so why do media outlets still quote them?

Canadian journalists should be wary of groups like the CTF, says Sociology Professor Kyle Willmott
Management

Using losses in a corporate group: An overview of loss consolidation

Brian Nichols and Kelsey Horning of GSNH on loss consolidation arrangements
Profession

Sunday News Roundup 21.12.12: Fiscal anchors, full of beans, Alta opinions, and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Practice

Tax Court rules that gift of shares of a private corporation to a foundation was ineligible for a charitable tax credit

Tax lawyer and accountant David J Rotfleisch on gifting non-qualifying securities such as a promissory note to a registered charity
Thought Leaders

CRA applying GAAR for outside/inside ACB misalignment on 55(3)(a) transactions

In the final part of a three-part series, Doug S. Ewens and Kenneth Keung of Moodys Tax Law ask whether the CRA is over-reaching on the scope of the GAAR
Thought Leaders

Our response to the CRA's position on creditor-proofing reorganizations – part 2 (a case study)

A three-part series from Doug S. Ewens and Kenneth Keung of Moodys Tax Law
Practice

What can a taxpayer do if a CRA decision letter is unclear?

Canadian accountant and tax lawyer David J Rotfleisch on a recent Federal Court decision against Canada Revenue Agency
Practice

When to file (and when not to file) a service complaint against the CRA

Pierre Alary of Gowling WLG on factors that support the filing of a service complaint as part of an ongoing tax dispute
Practice

Pandora Papers: More smoke than fire? CRA VDP operations manual: Top 10 takeaways

Stevan Novoselac and John A. Sorensen of Gowling WLG on the nuances of the CRA's VDP Operations Manual
Practice

Rectification and the vanishing prospects for common sense and compassion

John Sorenson of Gowling WLG asks whether the Glenmac decision demonstrates a tax system that is just, equitable and fair