With respect to the Income Tax Act, the Excise Tax Act and other fiscal legislation, the Tax Court of Canada
Act provides for relief from Notices of Assessment issued by the CRA.
noted, the Tax Court of Canada
had previously upheld the same provision in Charter challenges on the basis that the provision applies equally to all personsi Pagnotta v.
Radisson is satisfied with the decision of the Tax Court of Canada
which recognised that the expenses incurred by the corporation qualified as CEE for purposes of the Income Tax Act (Canada) and that all the property and equipment used were required and formed an integral part of the exploration project completed.
for example, the Tax Court of Canada
accepted the taxpayer's argument that the lease agreements that it had entered into in the course of its lease financing business "effectively transferred substantially all of the benefits and risks of ownership" to the lessees.
You will by now have heard that the Federal Court of Appeal reversed the decision of the Tax Court of Canada
, restoring the original assessment for income tax that we have been disputing for so many years.
The Tax Court of Canada
is the first level of appeal for taxpayers.
In fact, several Canadian tax payers have challenged the Canada Revenue Agency's treatment of these giving strategies in Canada's Tax Court and have won a full and complete consent to judgment in favour of the taxpayer from the Tax Court of Canada
(cite Navatos v.
In its Comprehensive Response of the Government of Canada to the Seventh Report of the Standing Committee on Public Accounts, the Department held open the possibility of retroactive legislation in response to adverse decisions by the Tax Court of Canada
The story does not end there, however, as the taxpayer may appeal to the Tax Court of Canada
The Court allowed the appeal of Revenue Canada and reversed the judgment of the Tax Court of Canada
which sustained the appeal of the Bank from the assessments for federal income tax for its 1986 and 1987 taxation years.
Tax Court and Donald Bowman, former Chief Justice of the Tax Court of Canada
, for a session on what works (and what doesn't) in tax litigation.
A judgement of the Tax Court of Canada
dated September 16, 1994 sustained the Bank's appeal from the reassessments by Revenue Canada for federal income tax for the Bank's 1986 and 1987 taxation years, on substantially all of the issues before the Tax Court.