Introduction – Research and development tax expenditures and credits The rules regarding SR&ED claims are set out in various parts of the tax act. Section 37 allows for the deduction of SR&ED expenditures while section 127 allows for taxpayers to claim ITCs for SR&ED. Through amendments in 1944 to...
Keehn v. The King, 2023 TCC 1 Keehn v. The King is the perfect illustration of the principle that there is no equity in tax law and of the tax courts choosing to enforce the ‘letter of the law’, regardless of how inequitable it may appear. It also provides...
Case Comment – Hillcore Financial Corporation v. The King Introduction: Proper Reply in Pleadings Before the Tax Court of Canada Tax pleadings initiate cases that go before the Tax Court of Canada. These pleadings consist of the Notice of Appeal by the taxpayer and the Reply by the CRA....
Oliveira v. The King (“Oliveria”) demonstrates the need for taxpayers to diligently follow the deadlines stipulated on the notices received from the Canada Revenue Agency (“CRA”). Deadlines stipulated on notices of assessments, reassessments, or confirmations are based upon Canadian tax legislation i.e., the Income Tax Act (“ITA”) and the...
Introduction: Settling Tax Litigation in Canada Tax settlements play a vital role in tax administration and enforcement. It would be burdensome and impractical to litigate every tax dispute in Tax Court. When entering settlement discussions with the Canadian tax-litigation lawyer for the Canada Revenue Agency, taxpayers must carefully assess...