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Category: Taxpayer relief

Interest relief decisions

Posted on: May 23, 2024 Last updated on: May 23, 2024 Written by: John Loukidelis
In two recent cases—Brand v Canada (Attorney General), 2024 FC 159, and Cassidy v Canada (Attorney General), 2024 FC 174—the Federal Court sent back CRA decisions denying relief for reconsideration because the decisions in question had failed to consider adequately…
Continue reading “Interest relief decisions”…

The CRA and ‘reasonableness’

Posted on: January 27, 2023 Last updated on: January 27, 2023 Written by: John Loukidelis
The taxpayer in Howard v Canada (Attorney General), 2022 FC 1673, over-contributed to her TFSA. The CRA denied her request for relief on the basis that she had not made a “reasonable error” when she relied on advice from her…
Continue reading “The CRA and ‘reasonableness’”…

Interest relief

Posted on: January 13, 2021 Last updated on: January 13, 2021 Written by: John Loukidelis
In Belchetz v Canada (National Revenue), 2020 FCA 225, the court considered whether the Minister had properly exercised her discretion to allow relief for 15 of the 30 (!) years for which interest had been outstanding. The issue before the…
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Dividend refunds and taxpayer relief

Posted on: October 18, 2018 Last updated on: October 18, 2018 Written by: John Loukidelis
In Bonnybrook Industrial Park Development Co. Ltd. v. Canada (National Revenue), 2018 FCA 136, the taxpayer failed to file tax returns for multiple years, which meant that it was beyond the three-year deadline for claiming a dividend refund. The taxpayer…
Continue reading “Dividend refunds and taxpayer relief”…

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Recent notes

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

Recent Posts

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

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Archives

Categories

Recent Posts

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

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