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David Spiro

David Spiro

Dentons


Latest Publications

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Federal Court Of Appeal Strikes Out A Pleading Alleging That Expenses Are Non-Deductible In Light Of “Egregious And Repulsive”...

In a ruling handed down May 6, 2013, the Federal Court of Appeal ordered that portions of a Crown pleading be struck out for suggesting that a deduction may be disallowed on the basis that the conduct of the taxpayer in...more

5/13/2013 - Canada Income Taxes Tax Deductions

Judicial Review Applications Challenging Minister’s Alleged Violation Of Voluntary Disclosure Policy And MAP Agreement Allowed To...

In Sifto Canada Corp. v. Minister of National Revenue, 2013 FC 214, Prothonotary Aalto of the Federal Court rejected the Crown’s motion to strike out judicial review applications filed by Sifto Canada Corp. challenging...more

4/15/2013

CRA Answers TEI’s Questions About Its New “Risk-Based Audit Process”

The Canada Revenue Agency has now published a set of answers to questions and concerns about the audit process presented to it by the Tax Executives Institute late last year....more

1/31/2013 - Audits CRA

Tax Executives Institute Raises Important Audit Process Questions And Concerns In Its Annual Meeting With The Canada Revenue...

Earlier this month, the Tax Executives Institute, Inc. (TEI) raised a number of important income tax administration issues in its annual meeting with the Canada Revenue Agency. Concerns were expressed about how the CRA...more

12/28/2012 - Audits Canadian Revenue Agency

Tax Court Of Canada Upholds General Policy That Settlement Agreements Should Be Respected – Taxpayer’s Waiver Of Right To Appeal...

In Noran West Developments Ltd. v. The Queen, the Tax Court of Canada (Justice Brent Paris) upheld the validity of a taxpayer’s waiver of its right to appeal executed following the conclusion of a settlement with the Appeals...more

12/24/2012 - Appeals Motions to Quash Right To Appeal Unconscionable Contracts Waivers

Extensive Amendments To Tax Court Of Canada Rules (General Procedure) Published In Part I Of The Canada Gazette

General Objectives of the Proposed Amendments The general objectives of the proposed amendments are: (1) to streamline the process of hearings and to codify the practice relating to litigation process...more

12/10/2012 - Evidence Expert Testimony

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