Introduction – Limit on Losses from Shares Held as Capital Property Subsection 112(3) of the Income Tax Act is a stop-loss rule that limits losses from the disposition of shares held as capital property. This provision applies when a taxpayer disposes of a share that has paid a dividend...
Canadian tax evasion may lead to imprisonment of up to 2 years The Canada Revenue Agency (CRA) operates a dedicated unit known as the Criminal Investigations Program. This division is responsible for investigating tax fraud, tax evasion, and other tax-related offences. When appropriate, it refers tax evasion cases to...
Introduction: Tax Litigation & Examination for Discovery The Tax Court of Canada, established in 1983 under the Tax Court of Canada Act, serves as a federal court that adjudicates disputes arising from tax matters between individuals or companies and the Canada Revenue Agency. The court’s jurisdiction primarily encompasses appeals...
In April 2025, the Federal Court of Appeal delivered its judgment on Total Energy Services Inc. v HMK, 2025 FCA 77, upholding the decision of the Tax Court of Canada in 2024 TCC 12 in February 2024. This case affirms the application of the general anti-avoidance rule (GAAR) under...