Archive for Month: December

Image of two woman on bed looking on laptop on the sleep country canada website

Rectification Saves Taxpayers from Adverse Tax Consequences arising from Drafting Error: Sleep Country Canada Holdings & Sleep Country Canada Inc v AGC, 2022 ONSC 6103 – A Canadian Tax-Litigation Lawyer’s Analysis

Introduction: Rectification & Its Tax Consequences Rectification is an equitable remedy. It allows parties to correct drafting errors that would otherwise render a legal instrument incompatible with the agreement that the instrument was meant to document. In these cases, the contracting parties may ask a court to rectify the...

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Federal Court granted CRA access to big box store’s client lists that may uncover tax fraud and evasion: Guidance from a Canadian tax lawyer on CRA’s power to compel third parties to disclose information

Big box store was ordered by the Federal Court to turn over its client lists to the CRA In November 2022, the Federal Court granted the CRA’s request to force J.D.Irving to turn over its clients’ data from January 1, 2019, which included the complete name, contact information, CRA...

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