Ludmer v. Attorney General of Canada, 2020 QCCA 697

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Summaries

Summary Under

CRA had abusively applied Reg. 7000(2)(d) to equity-linked notes and, thus, inconsistently with published positions

The Canadian-resident taxpayers were shareholders of a BVI company (“SLT”) which, in turn, held notes issued by two foreign subsidiaries of...

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Summary Under

abusive and wrongful CRA audit conduct did not engage punitive damages

CRA made unreasonable reassessments with the knowledge that they were contrary to advice received from Rulings, offered in a settlement offer to...

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