Featured Cases

The Supreme Court of Canada Decides Loblaw Financial Holdings Inc. - “President’s Choice” Brands the “Foreign Affiliate” Regime - Updated

  *This is an updated post that reflects helpful comments on the earlier post provided by a number of friends and colleagues who share my interest in this case and indeed the law more broadly. "Loblaws" is an established Canadian grocer. It markets a comprehensive line of high quality products and services, including financial services, […]

The Taxpayer is Successful Today at the Supreme Court in the Important Alta Energy "Treaty Shopping" Case - Updated

  What is "treaty shopping"? It is an often used and disparaging phrase in international tax practice. But, in fact few really know what it means, contrasted with what for various reasons they want it to mean. Today, we have a much better idea of what "treaty shopping" is not. We are also reminded in […]

Case Comment: Gladwin Realty Corporation v Canada (2020 FCA 142) A Narrow Approach to What Constitutes Abuse of SAAR

  In Gladwin Realty Corporation v Canada (2020 FCA 142), the Federal Court of Appeal upheld the Tax Court's finding of abuse relying on a GAAR analysis. However, the FCA reached its conclusion in a slightly different way than the Tax Court. The difference is indicated in two interesting comments that the Court made. One […]