Cases
Levett v. Canada (Attorney General), 2022 FCA 117
The resident applicants (principally Messrs. Levett and Baazov and a corporation owned by one of them) brought an application to have CRA requests...
Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2021 FCA 62
Art. 26(1) of the Canada-France Convention provided inter alia:
The competent authorities of the Contracting States shall exchange such...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.7 - Subsection 231.7(1) | Minister obtained compliance order re French request for trust details re French wealth tax | 313 |
Levett v. Canada (Attorney General), 2021 FC 295, aff'd 2022 FCA 117
The applicants (two couples and a corporation owned by one of them) brought an application to have CRA requests to the Swiss federal tax...
Hillis v. Canada (Attorney General), 2015 FC 1082
Ginny Hillis, who was born in the U.S. to Canadian-citizen parents and came to Canada when she was five, brought an action for a declaration that...
| 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 26A | Art. 26 of US Convention did not prohibit FATCA information exchanges | 174 |
Pacific Network Services Ltd. v. MNR, 2002 DTC 7585 (FCTD)
Although Article 26 of the Canada-France Income Tax Convention did not specifically provide (as did paragraph 2 of Article 27 of the Canada-U.S....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) | 98 | |
| Tax Topics - Treaties - Income Tax Conventions | 116 |
See Also
Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15
The Australian Tax Office, which suspected that a UK accounting firm was providing nominee directors and shareholders to UK-incorporated companies...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) | third party notices to UK accounting firm and banks did not require them to be given explanation why information required | 932 |
Administrative Policy
5 April 2015 CRA Press Release (respecting Panama Papers)
Recent media coverage raises questions about leaked documents from a Panama law firm relating to the offshore financial affairs of numerous...
22 March 2016 Internal T.I. 2016-0632941I7 - BEPS exchange of tax rulings
In the context of Canada’s BEPS commitment to exchange information with other countries on certain tax rulings, effective April 1, 2016 IC 70-6...
88 C.R. - F.Q.16
The taxes covered under the Convention do not include provincial taxes, and RC cannot ask for information on behalf of the province.
88 C.R. - F.Q.18
RC routinely provides copies of NR4 forms to the U.S.