Words and Phrases - "misrepresentation"
Harika v. The King, 2025 TCC 81
The taxpayer, who had been assessed beyond the normal reassessment period to treat a capital gain from the disposition of real property as a...
Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375
In order to avoid B.C. provincial income tax on a capital gain of $336.2 million which was realized on a sale in 2002 of a control block of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Solicitor-Client Privilege | not necessary to provide legal opinion to rely on having consulted legal counsel | 225 |
| Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) | no fixed place of “business” if no source of business income | 183 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | Marconi test of "business" applied outside source-of-income context | 154 |
| Tax Topics - Statutory Interpretation - French and English Version | "misrepresentation" informed by narrower French version | 109 |
9 November 2012 CTF Atlantic Roundtable, 2012-0465921C6 - CTF Atlantic - Statute Barred Years
1. What is "misrepresentation"?
There is no requirement that the person providing the information intended to deceive the CRA ... . ... [T]he...
Ver v. Canada, [1995] TCJ No. 593
The Minister's reassessment of the taxpayers' 1988 taxation year beyond the normal reassessment period, on the basis that various claimed expenses...
Nesbitt v. The Queen, 96 DTC 6045, [1996] 1 CTC 282 (FCTD)
In preparing the taxpayer's return, the taxpayer's accountant erroneously reported the taxpayer's share of a capital gain as $71,139.42 rather...
MNR v. Foot, 64 DTC 5196, [1964] CTC 317 (Ex Ct), briefly aff'd 66 DTC 5072 (SCC)
The taxpayer, who underreported his income in his returns but pleaded (p. 5197) that "he honestly believed in the truth of the information...