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Latest Blog Posts

Fraudulent conveyances and estate planning

CanLII Connects has posted a good article by Duncan J. Manson on fraudulent conveyances and estate planning. The article is BC-centric. Would the analysis be any different under Ontario law?

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Director due diligence

Ahmar v R, 2020 FCA 65, reminds us that a director is not duly diligent if he fails to remit HST in the hope that he can turn around the corporation’s business. This is true even where the director is an honest, hard-working business owner who injects his own money into the corporation to keep…

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Application denied

A taxpayer cannot bring an application for a court order preventing the CRA from exercising its power to demand records and information even where the taxpayer believes that the CRA would be estopped from issuing an assessment for a matter to which the records and information relate.

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Rectification revival

The BC courts continue to do their part to revive rectification as an important tool for fixing tax mistakes (or, more properly, delineate better the circumstances in which the tool can be used). See 5551928 Manitoba Ltd. (Re), 2018 BCSC 1482, aff’d 2019 BCCA 376. In Manitoba, the corporate taxpayer had declared an excess capital…

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