On April 24, 2017, the Tax Court of Canada rendered its judgment in Armour Group Ltd. v. The Queen. This case grapples with whether the taxpayer's land transactions with the Province of Nova Scotia resulted in deductible business income or a...
In the leading case of Maya Forestales S.A. v. The Queen, 2005 TCC 66, the Tax Court of Canada analyzed whether a non-resident corporation was carrying on business in Canada such that it would be liable to pay tax on its taxable income earned in...
We are excited to introduce Tax Foresight’s new navigator: T2057: Section 85 Election Eligibility. The T2057 navigator assesses whether a disposition of property by a taxpayer to a taxable Canadian corporation is eligible for an election under...
We are excited to introduce Tax Foresight’s new classifier: Directors’ Liability. The Directors’ Liability Classifier assesses a director’s liability by evaluating whether the due diligence defence is available, pursuant to s. 227.1(3) of the ...
Law and accounting firms across Canada are buzzing: Tax Foresight and Case Finder are revolutionizing tax law research. Our users are working smarter and more efficiently than ever, spending less time digging through keyword and boolean searches...
On April 21, 2017, the Tax Court of Canada rendered its judgment in Foote v. The Queen, 2017 TCC 61. As Tax Foresight correctly predicted with 95%+ confidence, the Court held that the taxpayer’s gains from trading in securities should be...
In the leading case of Johns-Manville Canada Inc. v. The Queen , [1985] 2 SCR 46, the Supreme Court of Canada set the standard for whether tangible expenditure is a current or capital What can we learn from this key decision? Our Tax Foresight...
In Feizmohammadi v. The Queen, 2017 TCC 28 the Tax Court of Canada held that the taxpayer’s condominium sale constituted income from a business. Tax Foresight correctly predicts the outcome of the Feizmohammadi case with 91% confidence.
On May 29, 2017, the Tax Court of Canada rendered its judgment in Struck v. The Queen, 2017 TCC 94, holding that the taxpayer’s corporation had conferred a shareholder benefit on the taxpayer by making mortgage payments for his personal residence.
The Canada Revenue Agency recently confirmed their concern about non-passive investments in TFSAs. When might this be an issue?