Income Tax Act

Daishowa-Marubeni: A Tree Fell In The Forest And The SCC Caught It!

In Daishowa-Marubeni International Ltd. v. The Queen, 2013 SCC 29, Justice Rothstein marries tax philosophy and tax practice by asking and answering the question: If a tree falls in the forest and you are not around to...more

Federal Court Of Appeal Deals A Blow To The Canada Revenue Agency: Full Disclosure Must Be Made On Ex Parte Applications

On February 21, 2013, the Federal Court of Appeal released two decisions related to the obligations of the Minister of National Revenue when making ex parte applications under subsection 231.2(3) of the Income Tax Act (the...more

A Pointed Observation By The Federal Court Of Appeal On The CRA’s Approach To Proposed Legislation

The recent Federal Court of Appeal decision of Edwards v. The Queen (2012 FCA 330) includes an interesting observation dealing with the Canada Revenue Agency’s policy with respect to proposed legislation....more