Source: Tax Law Link: Brief Overview of Tax History For most persons, tax is an “unpleasant subject” of complex and inexplicable rules, administered with bureaucratic ferocity and resulting in expensive litigation over an extended period. Tax law, however, has evolved over many centuries and is at the root of some of our most cherished values i

Source: Tax Law Link: Tax Reform, Less Talk and More Action, Please Tax policy should be concerned with the effectiveness and efficiency of compromises between a nation’s economic, social, cultural and political values. Canada last considered serious policy analysis in the Carter Commission Report, published after thorough and rigorous analysis i

Source: Tax Law Link: The Nature of Taxes As with a jigsaw puzzle, we need to look at the picture on the front of the box before we start putting the pieces together. Hence, we examine the nature and meaning of taxes, the constitutional authority to levy them, the analytical framework of fiscal legislation, administrative considerations and the pro

Source: Tax Law Link: Whose Income is It? In 1966, the Carter Commission recommended that the income tax system should consider the family (spouse and minor children) as the basic unit for determining tax liability. Canada did not accept the recommendation for various political reasons. As a result, the general rule in Canadian income tax law is th

Source: Tax Law Link: CRA’s Billion Real Estate Nut: Tough to Crack The Canada Revenue Agency (the “CRA”) recently published a news release (the “Release”), in which it identifies over $1 billion in unpaid taxes in the BC and Ontario real estate sectors since 2015. Nevertheless, it remains unclear how much of this amount will remain after

Source: Tax Law Link: .7M for CRA’s “Malicious Prosecution” Set Aside on Appeal The British Columbia Court of Appeal (the “BCCA”) reversed (the “Decision”) a landmark decision (the “Lower Court Decision”) that had awarded a B.C. couple (the “Samaroos”) $1.7 million in damages for the Canada Revenue Agency’s (the “CRA”) p

Source: Tax Law Link: Bribery and Corruption in International Business The SNC-Lavalin affair has dominated the Canadian news media for two months without complete revelation of what really happened. All that we know for sure is that SNC-Lavalin was charged with violations under the anti-corruption statute and that they sought a remediation agreeme