Archive for Category: Tax Court Settlement

Shadows of people running across money bills

Canadian taxpayer involved in a bad will investment scheme granted additional relief on accrued interest from Canada Revenue Agency (CRA): Barrs v The Queen et al.

In Barrs v The Queen et al, the taxpayer, Mr. Randall Barrs, appealed to the Federal Court of Appeal after the Federal Court dismissed his application for judicial review of the Canada Revenue Agency’s (CRA) decision to deny him additional relief from accrued interest. In 1984, Mr. Barrs and...

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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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