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FCTD (summary)
Midwest Oil Production Ltd. v. The Queen, 82 DTC 6092, [1982] CTC 107 (FCTD), aff'd 83 DTC 5304, [1983] CTC 338 (FCA) -- summary under Paragraph 12(1)(o)
Because s. 12(1)(o) taxes the producer, not the (Alberta) owner, of the petroleum, it does not contravene the constitutional prohibition against the taxation of provincial property. ...
FCTD (summary)
Canada (National Revenue) v. Friedman, 2019 FC 1583, aff'd 2021 FCA 101 -- summary under Section 13
Friedman, 2019 FC 1583, aff'd 2021 FCA 101-- summary under Section 13 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 13 s. 231.1(1) demand made in civil audit context did not contravene s. 13 The Friedmans, a married couple, who had not filed T1135 returns, each received Requests for Information under s. 231.1(1) (“RFIs”) that were addressed to them personally. ...
FCTD (summary)
Deegan v. Canada (Attorney General), 2019 FC 960, aff'd 2022 FCA 158 -- summary under Subsection 266(2)
Canada (Attorney General), 2019 FC 960, aff'd 2022 FCA 158-- summary under Subsection 266(2) Summary Under Tax Topics- Income Tax Act- Section 266- Subsection 266(2) Canada’s FATCA-related legislation does not contravene the Charter Mactavish J rejected the position of two American citizens, who had had no significant connection with the U.S. since early childhood, that the information-reporting requirements in ITA Part XVIII resulted in the unreasonable seizure of financial information belonging to U.S. persons in Canada, contrary to s. 8 of the Charter. ...
FCTD (summary)
Canada (National Revenue) v. Friedman, 2019 FC 1583, aff'd 2021 FCA 101 -- summary under Section 7
Friedman, 2019 FC 1583, aff'd 2021 FCA 101-- summary under Section 7 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 7 s. 231.1(1) demand made in civil audit context did not contravene s. 7 The Friedmans, a married couple, who had not filed T1135 returns, each received Requests for Information under s. 231.1(1) (“RFIs”) that were addressed to them personally. ...