Cases
Hillis v. Canada (Attorney General), 2015 FC 1082
One of the challenges brought by the appellant to the Canadian FATCA legislation (i.e., the Canada-United States Enhanced Tax Information Exchange...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | regard to object rather than political statements | 55 |
| Tax Topics - Treaties - Income Tax Conventions - Article 25 | FATCA requirements were reciprocal and were primarily imposed on financial institutions | 182 |
| Tax Topics - Treaties - Income Tax Conventions - Article 27 | FATCA information exchanged automatically irrespective of any substantive U.S. tax liability was "relevant" to U.S. tax administration | 387 |
Chua v. MNR, 2000 DTC 6527 (FCTD)
Article XXVI A of the Canada-U.S. Convention was contrary to section 15 of the Charter in light of the citizenship preference contained in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Subsection 15(1) | 30 |
See Also
Retfalvi v. USA (2019), No. 18-2158 (U.S.C.A., 4th Circuit)
The appellant (Retfalvi) became a U.S. citizen in 2010 and also was reassessed in 2010 by CRA respecting gains on two Canadian condo sales...
Ben Nevis (Holdings) Ltd. v. Revenue and Customs Commissioners, [2013] BTC 485, [2013] EWCA Civ 578
The most recent Income Tax Convention between the U.K. and South Africa had entered into force on 17 December 2002, and a Protocol providing for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | creation of new collection right did not entail retrospectivity | 182 |
| Tax Topics - Treaties - Income Tax Conventions | Vienna convention approach applies to non-signatories | 207 |
| Tax Topics - Statutory Interpretation - Revenue Rule | 124 |
Administrative Policy
25 July 2012 External T.I. 2011-0427221E5 - FBAR penalties
Penalties that the US collects for failure to report Foreign Bank and Financial Accounts information under form TD F90-22.1 ("FBAR penalties") are...
28 December 2000 External T.I. 2000-0003915 - Article XXVI A of Canada-US Tax Treaty
General discussion of Article XXVI A of the Canada-U.S. Convention.