No Password Required: Education Lead at Semgrep and Former Czar for Canada’s Election Security
4 Key Takeaways | Major U.S. Supreme Court Trademark & Copyright Decisions
Hidden Traffic : New Human Trafficking and Child Labor Regulation in Canada with Sean Stephenson
[Podcast] Catching Up on Canadian Environmental Regulation
[Podcast] USMCA in Review, with C.J. Mahoney, Former Deputy U.S. Trade Representative
Episode 4 - USMCA and the trade relationship between the U.S.A, Mexico, & China
Five Questions, Five Answers: Electric Mobility Canada on Its Promises for a Cleaner Economy
Five Questions, Five Answers: The Voice of Canadian Automotive Parts Manufacturers
The Great Green North: A Discussion on Canada’s Environmental Regulations
Blakes Continuity Podcast: Cutting Through the Weeds: A Look at Environmental Issues Impacting Businesses
Balado continuité – Environnement : nouveautés du régime d’autorisation québécois
Blakes Continuity Podcast: What to Expect When Insolvency Crosses the Border
Infrastructure and Indigenous Engagement
A Way Forward: Energy Industry Ready to Fuel Canada's Recovery
Blakes Continuity Podcast: The Moving Landscape of Foreign Investments
Blakes Continuity Podcast: COVID-19: The Regulatory Impact on Pensions
Employment and Labour in the Time of COVID-19
Nota Bene Episode 70: Examining the USMCA: Is it Simply a Rebranded NAFTA? with Scott Maberry
This Week in FCPA-Episode 96, 2018 - the Opening Day edition
Exporting ERISA After Walter Canada
On June 27, 2023, the Tax Court of Canada (“TCC”) dismissed the appeal of a Schedule II bank (the “Bank”) regarding its entitlement to input tax credits (“ITCs”) for GST/HST payable on expenses incurred in connection with the...more
On June 8, 2023, the Federal Court of Appeal upheld a Tax Court of Canada decision that, by allowing a supplier of Automated Teller Machines (“ATMs”) to place and operate ATMs throughout its casino resort, a casino operator...more
In an informal procedure decision, Axelrod v. The King, rendered on December 12, 2022, the Tax Court of Canada dismissed the appeals of a dentist denying input tax credits (“ITCs”) claimed in connection with certain expenses...more
On July 19, 2022, the Tax Court of Canada (“TCC”) dismissed a major Canadian Bank’s appeal (the “Bank” or the “Appellant”) regarding the characterization of a supply made by the President’s Choice Bank (“PCB”) to the Bank....more
On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more
Due to the complexity of Canadian tax law, it is not uncommon for taxpayers and the minister of national revenue to refine their respective positions and identify new arguments and issues in the course of the tax dispute...more
Across the globe, courts have rapidly adapted their practices and procedures in response to the COVID-19 pandemic. As waves of infections have spread throughout Canada, its courts have fluctuated between resuming activities...more
In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more
The Me Too movement of the last few years and recent worldwide protests sparked by George Floyd's killing have focused welcome attention on combatting gender and racial discrimination and harassment. A recent Tax Court of...more
Fast Tracking to Normal - Chief Justice Rossiter and Associate Chief Justice Lamarre of the Tax Court of Canada provided an update on the resumption of operations of the Tax Court to the members of the Canadian Bar...more
Update from the Tax Court - On May 14, 2020, Chief Justice Rossiter and Associate Chief Justice Lamarre of the Tax Court of Canada provided an update on the resumption of operations of the Tax Court to the members of the...more
On April 23, 2020, the Federal Court of Appeal (FCA) allowed the taxpayer’s appeal of the Tax Court of Canada (Tax Court) decision in Loblaw Financial Holdings Inc. v. The Queen. The case involved almost C$475-million of...more
Practice Directions and Notices to Profession - On April 17, 2020, the Tax Court of Canada released both a Notice to the Public and the Profession and a Practice Direction and Order. The April Notice expands upon the...more
The COVID-19 outbreak prompted the following notices or directions from the federal courts which deal with tax matters....more
Pangaea One Acquisition Holdings XII S.À.R.L. v. The Queen, 2020 FCA 21 - The Federal Court of Appeal has upheld the decision of the Tax Court of Canada (2018 TCC 158, Smith J.), confirming that a payment made to induce a...more
Overview of Rule 26 - Section 26 of the Tax Court of Canada Rules (General Procedure)1 (the "Tax Court Rules"), referred to as "Rule 26", can be useful where multiple taxpayers are involved in related matters and are...more
The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more
In a case of first impression, the Tax Court held that the U.S.–Canada Tax Treaty (Treaty) did not exempt a Canadian citizen from U.S. income tax on the unemployment compensation she received from the State of Ohio. Pei Fang...more
The Federal Court of Appeal has limited the Canada Revenue Agency's (CRA) access to tax accrual working papers that reveal a taxpayer's uncertain tax positions. This case is an important one for every company that has audited...more
Two recent decisions of the Tax Court involving the general anti-avoidance rule (GAAR), Univar Holdco Canada ULC v The Queen, 2016 TCC 159 [Univar] and Oxford Properties Group Inc v The Queen, 2016 TCC 204 [Oxford...more
The Tax Court of Canada has recognized in a recent case that “oversight expenses” – notably investment banking and other professional advisory fees for services rendered to boards of directors in their discharge of oversight...more
Bennett Jones LLP represented Feedlot Health Management Services Ltd. (FHMS) in the recent Tax Court of Canada proceeding, Feedlot Health Management Services Ltd v The Queen (2015 TCC 32). The case concerned certain...more
The Tax Court of Canada recently confirmed in International Hi-Tech Industries Inc v The Queen, 2014 TCC 198, that in certain circumstances a secured creditor can commence or continue a tax appeal on behalf of a bankrupt...more
In Baldwin et al v the Queen, 2014 TCC 284, the Tax Court of Canada had an opportunity to consider section 87 of the Indian Act and when employment income is “situated on a reserve” for tax purposes....more
The recent decision in Bolton Steel Tube Co. Ltd. v. The Queen, 2014 TCC 94, confirms that the CRA is required to reassess a taxpayer in accordance with terms of settlement. In its decision, the Tax Court provides useful...more