The Court found that intimations under Sections 143(1) and 154(3) were not communicated due to technical reasons. The matter was remitted for fresh consideration after a revised audit report was ...
On October 30, 2019, the British Columbia Court of Appeal upheld the rectification of an erroneously calculated capital dividend account, saving the corporate taxpayer from a punitive 60% tax. In ...
A drafting mistake in an agreement can result in significant and unintended tax consequences. In the recent case of Baytex Energy Ltd. v. Canada (Attorney General) (Baytex), the Court of Queen’s Bench ...
The trust sought exemption by invoking later registration under section 12AA. The tribunal ruled that exemption cannot be granted retrospectively through section 154 when no assessment was pending on ...
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