63) See generally An Act to amend the Tax Court of Canada
Act and other Acts in consequence thereof, SC 1988, c 61, s 18(1), which repealed sections 172(1) and (2) of the ITA, and allowed appeals to either the Tax Review Board or Federal Court upon the filing of an appeal under section 165 of the ITA.
The News Release also proposed to amend the Tax Court of Canada
Act to allow the monetary threshold to be increased further to $50,000 (or $100,000 in losses) by regulation.
Taking this logic back to the Tax Court of Canada
, the MIL Investments case ultimately stands for a tax regime that is freshly minted for the twenty-first century and as ripe as a nineteenth century chestnut.
Based on the same underlying behaviour of the parties, the Tax Court of Canada
and the Federal Court of Appeal used two different approaches to facilitate two completely different tax results.
On June 22, 2016, the Tax Court of Canada
issued a judgment in favor of the CRA.
In January 2016, the Federal Court of Appeal affirmed the decision of the Tax Court of Canada
in Marzen Artistic Aluminum Ltd.
However, a recent Tax Court of Canada
decision (Andrew Peller Limited vs.
It is because Duncan wrote a character reference letter in June 2011 to the Tax Court of Canada
on behalf of a constituent.
The Tax Court of Canada
was called upon to decide pursuant to the Convention whether the Appellant was required to pay to Canada the income tax on his Canadian business income.
Describing the Ali appellants' circumstances as "certainly sympathetic", (50) Justice Woods in the Tax Court of Canada
(although referring to the distinction in Auton between benefits which were and were not provided under the legislation) proceeded to an analysis of whether there had been a breach of section 15.
Beyond that CRA rulings can be appealed to the Tax Court of Canada
and the Federal Court of Appeal.
The recent Tax Court of Canada
case of Gernhart is the first to address the taxability of tax equalization payments.