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Canada Tax Liability Corporate Taxes

Dickinson Wright

Tax Planning Misstep? Ontario Court of Appeal Says No to Rectification

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A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more

Stikeman Elliott LLP

Raising New Arguments and Issues in Tax Litigation

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Due to the complexity of Canadian tax law, it is not uncommon for taxpayers and the minister of national revenue to refine their respective positions and identify new arguments and issues in the course of the tax dispute...more

Stikeman Elliott LLP

GST/HST Elections: Why Being Late Is Not Always Fashionable (Cont’d)

Stikeman Elliott LLP on

On December 6, 2021, the Federal Court of Appeal (“FCA”) affirmed the Federal Court’s decision in Denso Manufacturing Canada Inc. v. Canada (National Revenue), which had dismissed the taxpayers’ application for judicial...more

Bennett Jones LLP

Taxpayer Loses Canadian Transfer Pricing Case

Bennett Jones LLP on

A recent transfer pricing case from the Tax Court of Canada (McKesson Canada Corporation v The Queen) establishes a broad interpretation of the “regular” (non-recharacterization) transfer pricing rule in the Income Tax Act...more

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