Tax Disputes Tax Disputes

The structure of a pleading: The B.C. Court of Appeal provides guidance on the drafting of responses and counterclaims

Osler’s Sergio Ortega provides his analysis of the B.C. Court of Appeal’s reaffirmation of the importance of complying with formal requirements...

Canadian federal government releases significant package of draft tax legislation

Finance Canada releases significant draft tax legislation, including new limits on interest deductions and expanded CRA audit powers.

Loblaw Financial wins tax appeal at Supreme Court of Canada

Loblaw Financial wins tax appeal at Supreme Court of Canada, with implications for tax planning and Canadian parent companies with subsidiaries...

Supreme Court releases Alta Energy decision: taxpayer wins, application of GAAR to tax treaties clarified

Earlier today, the Supreme Court of Canada released its decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.

Continued uncertainty following recent CRA position on Tax Treaty anti-avoidance rule

The most significant treaty modification implemented through the MLI was the addition of a broad anti-avoidance rule known as the principal purpose...

Supreme Court denies Crown’s request for leave to appeal Cameco transfer pricing decision

On February 18, 2021, the Supreme Court of Canada declined the Crown’s application seeking leave to appeal the June 2020 decision of the Federal...

Federal Court of Appeal decides that Visa services to CIBC are exempt financial services, not administrative services for GST/HST purposes

On January 22, 2021 the Federal Court of Appeal released its reasons in Canadian Imperial Bank of Commerce v. The Queen, 2021 FCA 10, overturning the...

Litigating during COVID-19 and other notable litigation developments in 2020

In March 2020, the COVID-19 pandemic forced many courts and tribunals to shut their doors. This article highlights a number of the changes and...