When a Canadian taxpayer tried to change his 2004 tax return, CRA declined and pushed for penalties plus interest while ignoring his change request for 10 years. Judicial review sided with the taxpayer. In 2005, anticipating that his 2004 reportable income would be nearly double the amount originally declared,...
Introduction: Canadian Charity Law, CRA Revocation, and Constitutional Jurisdiction The British Columbia Supreme Court decision in Coram Deo Foundation v MNR, 2026 BCSC (S260171), is a significant Canadian charity law and Canadian tax litigation ruling addressing interim injunctive relief, CRA revocation of charitable status, and constitutional limits on federal...
In Insurance Institute of Ontario v. M.N.R., 2020 TCC 69, the Tax Court of Canada clarified that where a payor and a worker share a common intention regarding the nature of their relationship, that intention may prevail — even where the objective indicia point in a different direction —...