Another Court Finds CRA Owes Duty of Care… But only kinda…

Canadian Tax Haiku of the Week: Duty of care for Tax shelters? Is it really All CRA’s fault? Introduction In Scheuer,[1] a group of taxpayers who participated in a tax shelter donation scheme made a claim in negligence against the Canada Revenue Agency (“CRA”). The...

Employee or Contractor for Canadian Tax Purposes?

Ontario Real Estate Association v MNR, 2014 TCC 190 Link to Court Document Canadian Tax Haiku of the week: Am I Contractor? Or Employee? If unsure Just follow the test Introduction A trend emerging within the Canadian workforce has been the increase of out-sourcing...

McKesson: When Advocacy “Boyles Over”

Canadian Tax Haiku of the Week: Transfer pricing Judges need justice too in McKesson Canada IntroductionOn December 20, 2013, the Tax Court of Canada (“Tax Court”) released an eagerly anticipated 105-page verdict involving the latest Canadian transfer pricing trial,...