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14 February 2018- 12:53am Morrison – Federal Court of Canada finds that CRA appropriately denied s. 163(1) penalty relief for failure to notice the accountant’s T4 omission Email this Content The taxpayer's accountant inexplicably failed to include a T4 for $47,770 in the taxpayer’s return. ...

5 February 2019- 12:44am Xia – Tax Court of Canada finds that a gross negligence penalty applied for failure to check out an exempt receipt theory re tips Email this Content A well-educated slot attendant at a casino, who doubled his income through the receipt of his share of tips, was subject to a gross negligence penalty for failure to report the tip income given inter alia his failure to consult with anyone respecting his position that the tips were non-taxable as being a share of exempt lottery winnings. ...

20 February 2019- 12:13am Shallhorn – Court of Quebec finds that the cost to a paraplegic person of installing a home elevator was an eligible medical expense Email this Content Laurin J found that a paraplegic person, who incurred approximately $80,000 to install an elevator in his home, which thereby gave him access to all floors, was entitled to a medical tax credit under the Quebec equivalent of ITA s. 118.2(2)(l.2). ...

25 July 2019- 12:42am Masson – Federal Court finds CRA reasonably declined to grant a late s. 85 election Email this Content In finding that it was reasonable for CRA to deny the taxpayer’s request to file a late s. 85(1) election respecting transfers made by him quite a number of years previously, Roussel J stated: Considering that no evidence was presented to show the initial intention to proceed by rollover under subsection 85(1) of the ITA and that the errors of a third party do not constitute circumstances that justify a late election, it was open to the Minister’s representative to exercise her discretion to deny Mr. ...

26 August 2019- 11:14pm MacDonald – Tax Court of Canada finds that commuter air fares were not deductible employment expense Email this Content The taxpayer flew on a close-to-weekly basis back and forth between his Ottawa home (where he claimed to have a home office) and the Regina office of his employer. ...

29 November 2019- 12:01am Wiegers – Tax Court finds that it has no jurisdiction to order the renewal of a settlement offer Email this Content In rejecting the taxpayers’ request for an order requiring the Minister to make a settlement offer to the taxpayers consistent with that previously made (supposedly unbeknownst to the taxpayers) to other participants in the same gifting tax shelter, MacPhee J stated: [I]t remains clear and obvious, upon a review of the jurisdiction of the Tax Court as listed at section 171 of ITA, I cannot force either the Minister nor the Respondent to remake an expired settlement offer to an appellant. ...

29 December 2019- 11:50pm Schwartz – Quebec Court of Appeal indicates that the Court of Quebec lacked the jurisdiction to cancel interest attributable to its own delays Email this Content A Court of Quebec judge cancelled part of the interest included in the ARQ assessment attributable to a delay in the hearing due to the illness of the judge and counsel for the ARQ. ...

8 September 2020- 11:10pm Valovic – Tax Court of Canada finds that shareholders’ services were not consideration for dividends received by them for s. 160 purposes Email this Content An electrician and his spouse provided their services as electrician and administrator to their equally-owned corporation, and received dividends and salary. ...

18 October 2020- 11:47pm Sun – Tax Court of Canada finds that there was a supply of a condo directly from the builder to the assignee of the purchase contract for GST new housing rebate purposes Email this Content One of the requirements for the GST (or Ontario HST) new housing rebate is that there be a sale to the purchasing individual by the “builder.” ...

12 May 2021- 11:04pm Kam-Press – Federal Court of Appeal confirms requirement for use of the scientific method in SR&ED Email this Content A taxpayer acknowledged that the work performed by it for which it claimed investment tax credits did not follow the scientific method as described in Northwest Hydraulics, but argued that “there was no reference to ‘scientific method’ in the text of the definition [of SR&ED].” ...