Shaira Nanji

Shaira Nanji

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Devon: TCC considers large corporation rules

In Devon Canada Corporation v. The Queen the issue is whether the taxpayer (“Devon”) may deduct $20,884,041 paid to cancel issued stock options. After the close of pleadings, the Crown brought a procedural motion relating to...more

9/18/2014 - Canada Corporate Taxes Income Tax Act Income Taxes Stock Options Tax Deductions

McKesson: Trial Judge Recuses Self From Two Remaining Issues in Transfer Pricing Case

In McKesson v. The Queen (2014 TCC 266), Justice Patrick Boyle recused himself from the two remaining issues with which he was seized in the transfer pricing case – costs and the content of the court’s public file (i.e., the...more

9/11/2014 - Recusal Transfer Pricing

McKesson: Respondent’s Factum Filed

Earlier this year, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14). At...more

8/27/2014 - Canada Corporate Taxes Income Taxes McKesson Technologies

McKesson: Appellant’s Factum Filed

On January 10, 2014, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14)....more

6/26/2014 - Appeals Canada Corporate Taxes Income Taxes Tax Liability

CRA Update: Aggressive Tax Planning

At the Toronto Centre Canada Revenue Agency & Tax Professionals Breakfast Seminar on June 10, 2014, the Canada Revenue Agency (“CRA”) provided an update on selected CRA Compliance Measures in the Aggressive Tax Planning...more

6/12/2014 - Canada Income Taxes Revenue Tax Planning

International And Transfer Pricing Audits: Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar

At the Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar on February 18, 2014, the CRA provided an update on international and transfer pricing audits. The slides can be found here. The discussion was led...more

2/21/2014 - Canada CRA Money Transfer Transfer Pricing

CRA’s New Pre-Rulings Consultations Service

On November 26th, 2013, the Canada Revenue Agency (“CRA”) participated in a Roundtable session at the 65th Annual Tax Conference of the Canadian Tax Foundation held in Toronto, Ontario. The panelists announced a one-year...more

11/29/2013 - Canada Canadian Revenue Agency Income Taxes

Highlights From The Toronto Centre CRA & Professionals Group Breakfast Seminar (Objections And Appeals) – November 6, 2013

On November 6, 2013, at the Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar, representatives from the CRA provided an update on objections and appeals. Anne-Marie Levesque, Assistant Commissioner...more

11/8/2013 - Canada Compliance CRA Debt Collection DOJ

The Crown Succeeds On A Motion To Strike A Portion Of The Taxpayer’s Pleading: Golini V. The Queen

In Paul C. Golini v. The Queen (2013 TCC 293) the Tax Court of Canada agreed to strike out portions of a taxpayer’s pleading suggesting that a protective reassessment issued by the Canada Revenue Agency (“CRA”) was...more

10/3/2013 - Canada Income Tax Act Income Taxes Motion To Strike Pleadings Reassessments Tax Assessment

GAAR At 25: Panelists Discuss Lessons Learned And Challenges

On September 26, 2013, the Canadian Tax Foundation Young Practitioners Group (Toronto) convened a panel discussion titled “GAAR at 25: Lessons Learned & Current Challenges” on the General Anti-Avoidance Rule (“GAAR”) in...more

9/30/2013 - Anti-Avoidance Canada Income Tax Act Tax Evasion

Will The Tax Court Of Canada Entertain A Determination Of A Question Of Law Where The Focus Is On Future Assessments?

In Sentinel Hill Productions IV Corporation v. The Queen (2013 TCC 267), Justice Judith Woods of the Tax Court of Canada said no. In so doing, she shed light on the requirements for making an application for a determination...more

9/11/2013 - Canada Income Taxes Pleadings Tax Assessment

Get It Right The First Time: Newfoundland Transshipment Ltd. v. The Queen

In Newfoundland Transshipment Ltd. v. Queen (2013 TCC 259), the Tax Court of Canada dismissed an application by Newfoundland Transshipment (“NTL”) for an order to extend time to serve notices of objection for its 2002 to 2005...more

8/30/2013 - Asset Valuations Canada CRA Depreciation Pipelines

Waiving Rights Of Objection And Appeal: SCC Declines To Hear The Taxpayer’s Appeal In Taylor v. The Queen

On August 15, 2013, the Supreme Court of Canada dismissed the application for leave to appeal in Terry E.Taylor v. Her Majesty the Queen (2012 FCA 148). In Taylor, the issue was whether a signed settlement agreement...more

8/27/2013 - Canada Excise Tax FCA Gross Negligence GST Income Taxes SCC

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