Larry Nevsky

Larry Nevsky

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Brent Kern Family Trust: FCA Dismisses Appeal

In Brent Kern Family Trust v. The Queen (2014 FCA 230), the Federal Court of Appeal dismissed the taxpayer’s appeal with reasons delivered from the bench. The taxpayer had argued that the decision of Canada v. Sommerer (2012...more

11/18/2014 - Canada Tax Court Trusts

Bolton Steel Tube: TCC Orders Crown to Reassessment in Accordance with Settlement

In Bolton Steel Tube Co. Ltd. v. The Queen (2014 TCC 94), the Tax Court of Canada allowed the taxpayer’s motion requesting an Order that would require the CRA to reassess the taxpayer in accordance with the terms of a...more

6/27/2014 - Canada Corporate Taxes CRA Settlement Tax Court

McIntyre: Not What You Bargained For?

When are the parties to a civil tax dispute bound by agreed facts from a criminal proceeding? This was the question considered by the Tax Court of Canada on a Rule 58 motion made by the taxpayers in McIntrye et al v....more

4/18/2014 - Canada Collateral Estoppel Income Taxes Res Judicata Tax Liability

SCC Grants Leave To Appeal In Guindon v. The Queen

The Supreme Court of Canada has granted leave to appeal in Guindon v. The Queen (Docket # 35519). In this case, the Supreme Court of Canada will consider whether penalties imposed under section 163.2 of the Income Tax Act...more

3/24/2014 - Appeals Canada Income Tax Act Income Taxes SCC

Tax Court Upholds Penalties Imposed For False Statements

In Morton v. The Queen (2014 TCC 72), the Tax Court of Canada upheld penalties imposed by the Minister of National Revenue (the “Minister”) under subsection 163(2) of the Income Tax Act (Canada) (the “Act””) despite novel...more

3/20/2014 - Canada False Statements Income Taxes Penalties

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