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Category Archives: Tax

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Supreme Court safeguards solicitor-client privilege from requests under the Income Tax Act

Posted in Civil Litigation, Tax
Comment

In companion cases released on June 3, 2016, the Supreme Court of Canada (the “SCC”) confirmed the central importance of solicitor-client privilege to the rule of law in Canada. In Canada (National Revenue) v. Thompson, 2016 SCC 21, and Canada (Attorney General) v. Chambre des notaires du Québec, 2016 SCC 20, the Court considered provisions… Continue Reading

The Supreme Court of Canada takes a cautious step toward approving Agreements correcting errors in Tax Planning and Implementation

Posted in Tax
Comment

On November 28, 2013, the Supreme Court of Canada released one decision in two appeals concerning a taxpayer’s ability to correct an error in an agreement entered into for tax planning purposes.  Although Quebec (Agencie du Revenu) v. Services Enviromementaux AES inc., 2013 SCC 65 (“AES”), dealt with this issue under the Quebec Civil Code, it… Continue Reading