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The case of Blake v. Ahmed (2025 BCCA 384) concerns a dispute between a taxpayer and government authorities over the collection of unpaid taxes. The British Columbia Court of Appeal was asked to determine whether the lower court was correct in dismissing most of the taxpayer’s claims w...
In 2251102 Ontario Inc. v. The King, 2026 TCC 61, the Tax Court of Canada considered whether a taxpayer can successfully challenge a tax reassessment based on a net worth analysis where the CRA has relied on indirect methods due to inadequate books and records.
The case arose from...
The case of Ebert v. The King (2023 TCC 49) was decided by the Tax Court of Canada in April 2023. The case involved three taxpayers—Irving Ebert, Richard Herman, and P. Philippe DesRosiers—who had donated bottles of wine to registered charities and claimed charitable donation tax credi...
Canada’s non-resident trust regime under section 94 of the Income Tax Act is one of the most significant anti-deferral frameworks in Canadian international tax law. Following the 2007 legislative tax reforms, the provision greatly expanded Canada’s ability to tax offshore trust structures connected to Canadian...
Canada’s trust reporting framework has undergone significant reform in recent years as part of broader efforts to improve tax transparency and prevent tax avoidance through undisclosed beneficial ownership arrangements.
The Canada Revenue Agency (CRA) now requires many trusts to provide sub...