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25 May 2021- 11:40pm Logix Data – Tax Court of Canada finds that alleged SR&ED work was routine engineering Email this Content A taxpayer’s SR&ED claims for work on solar shingles installations were denied by Monaghan J on various bases including that the taxpayer did not have enough knowledge of the field to identify whether its work was advancing the state of knowledge, its work addressed routine engineering challenges and its documentation of the supposed SR&ED work was paltry and not prepared contemporaneously with the work. ...

18 July 2021- 10:57pm Mariani – Supreme Court of Ontario orders a new trial regarding claiming wedding expenses as business expenses Email this Content The trial judge convicted the individual accused and the corporation he owned (“MMFL”), of making a false statement and tax evasion in relation to both personal and corporate income tax returns. ...

17 January 2022- 10:47pm Dias – Tax Court of Canada denies ABILs to 2 individuals who lent to their SBCs through their Loanco rather than directly Email this Content The two individual taxpayers made loans to their two start-up retail-business companies (which were small business corporations) through another corporation (“201”) owned by them (which was not an SBC), rather than directly. ...

29 March 2022- 10:40pm Fortier – Federal Court finds a violation of procedural fairness where the taxpayer was not given a chance to respond Email this Content A CRA agent reviewed an individual’s application for CERB benefits, then contracted the individual’s former employer directly, and was told that he had left employment because his contract had reached its termination date, rather than for COVID reasons. ...

8 February 2024- 11:16pm Cassidy – Federal Court reverses CRA’s declining to provide significant interest relief due to its failing to engage with the taxpayer’s financial hardship request Email this Content The taxpayer requested interest relief under s. 220(3.1) primarily based on his inability to pay due to his divorce, the 2008 economic downturn, and the COVID-19 pandemic. ...

26 January 2025- 10:47pm Vorsteveldt – taxpayers are challenging the CRA administration of the 2/3 CGIR Email this Content Ms. ...

4 March 2025- 10:37pm RTI – Court of Quebec confirms that it had no jurisdiction to deal with over-remittances of source deductions Email this Content Couture JCQ confirmed that the Court of Quebec had no jurisdiction to consider a Notice Of Objection of the taxpayer based on the failure of the ARQ to refund source deductions which it alleged that it had over-remitted, given that the Quebec equivalent of ITA s. 171(1) only accorded the Court of Quebec jurisdiction to deal with assessments. ...

28 August 2017- 12:42am Radelet – Tax Court of Canada finds that the threat of a gross negligence penalty imposition was not “duress” vitiating a waiver Email this Content In addition to rejecting the (self-represented) taxpayer’s largely unsupported allegations that he had lacked mental capacity when he executed a waiver (extending the normal reassessment period so that CRA could await his submissions respecting what it considered to be an unreported capital gain of $445,551 and a questionable business loss of $400,000), Bocock J also rejected the taxpayer’s submission that the waiver had been executed under the “duress” of a threat of a gross negligence penalty- which was not untoward in the context of an unreported capital gain. ...

21 January 2018- 11:15pm Archibald – Federal Court of Appeal confirms that taxpayers cannot rely on favourable CRA treatment of similarly-situated taxpayers Email this Content In the course of dismissing the taxpayer’s appeal of an assessment made on the basis that tuition fees paid to the University of Liverpool for an on-line MBA program did not qualify for the tuition tax credit, Woods J.A. stated that it is “well settled that a taxpayer does not become entitled to relief simply because another taxpayer similarly situated was assessed differently.” ...

15 July 2018- 11:45pm Sterritt – Tax Court of Canada states that the Ontario Superior Court of Justice or the Federal Court, not it, had the jurisdiction to order a refund Email this Content Russell J stated that he lacked jurisdiction to order CRA to pay a refund to the taxpayer: [S]eeking that the Minister be ordered to issue the refund is not an aspect of deciding if an assessment or reassessment or a notice of loss determination is right or wrong. ...