Archive for Month: April

Judge with gavel in a courtroom

Blake v. Ahmed (2025 BCCA 384): The Court Says, Bring Real Arguments, Not Organized Pseudo-Legal Commercial Arguments (OPCA) —or Don’t Bring a Case

Introduction: Not every case needs a trial: how judges handle baseless arguments and claims The case of Blake v. Ahmed (2025 BCCA 384) concerns a dispute between a taxpayer and government authorities over the collection of unpaid taxes. The British Columbia Court of Appeal was asked to determine whether...

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Young brunette business woman holding full paper bin of crumpled receipts

2251102 Ontario Inc. v. The King – CRA Net Worth Tax Reassessments Triggered by Taxpayer’s Bad Bookkeeping, Lack of Receipts; CRA’s Reassessment Process Hard to Fight Against

Overview – The Burden to Challenge the Factual Basis of the Tax Reassessment In 2251102 Ontario Inc. v. The King, 2026 TCC 61, the Tax Court of Canada considered whether a taxpayer can successfully challenge a tax reassessment based on a net worth analysis where the CRA has relied...

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