Principal Issues: (1) Whether CRA’s comments on the meaning of "actively engaged on a regular and continuous basis" expressed in the context of...

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Principal Issues: Can the remaining balance of financing fees be written off in a taxation year where the borrowing to which they relate is...

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Principal Issues: Is a taxpayer considered to be performing duties of a temporary nature for the purpose of subparagraph 6(6)(a)(i)?

Position: Yes...

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Principal Issues: 1. Does the payment qualify as a royalty prepayment ? 2. Should the payment be included into income as per paragraph 12(1)(a) or...

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Principal Issues: In a particular situation, Aco holds all of the issued and outstanding shares of the capital stock of Bco. Both corporations are...

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Principal Issues: 1) Whether a family season ski and snowboard pass offered by an employer to his/her employees is a taxable benefit in a given...

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Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to...

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Principle Issues: Is the reimbursement by an employer of certain moving expenses incurred by an employee a taxable benefit under paragraph 6(1)(a)...

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