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Tax law

Gerald Kowarsky Trust v. His Majesty the King

The Tax Court held that a wound-up trust’s final taxation year ends on December 31, so the trust’s 2023 return was late and the penalty stood.

  • Income tax act
  • Trust taxation year-end
  • Late-filing penalty
  • Trust wind-up
  • Due diligence defense
  • Trust-taxation-year-end
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Tax law

Honey v. The King

Deux appels fiscaux liés à des prêts ICF dans des montages d’assurance vie 10/8 sont rejetés; le tribunal confirme un taux d’intérêt déductible de 4,18 %.

  • Income tax act
  • Interest deductibility
  • Reasonable amount of interest
  • 10/8 life insurance policy
  • Reassessment
  • Interest-deductibility
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Tax law

Kane v. The King

The Tax Court dismissed Paul Kane’s appeal from a 2009 reassessment, upholding a penalty under s. 163(2) of the Income Tax Act for wilful blindness to a fictitious business loss.

  • Income tax act
  • Section 163(2) penalty
  • Wilful blindness
  • Fictitious business loss
  • Misrepresentation
  • Income-tax-act
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Tax law

Chennenkunnath v. The King

The Tax Court allowed the appeal in part, denying most claimed employment expenses but leaving the conceded flyer-distribution deductions and cancelling subsection 163(2) penalties.

  • Income tax act
  • Employment expenses
  • Motor vehicle expenses
  • Telephone expenses
  • Work space in the home
  • Gross negligence penalties
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Tax law

Tchiakoua v. The King

The Tax Court allowed Ms. Tchiakoua’s appeal, holding that a $5,423 Quebec student loan remission was not taxable under paragraph 56(1)(n).

  • Income tax act
  • Taxability of student loan remission
  • Paragraph 56(1)(n)
  • Bursary definition
  • Tax-law
  • Income-tax-act
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Tax law

Denning v. The King

The Tax Court bifurcated Denning’s 2006 appeal into GLGI and Royal Crown Gold proceedings and struck the GLGI portion without leave to amend.

  • Income tax act
  • Bifurcation
  • Donative intent
  • Abuse of process
  • Motion to strike
  • Access to information disclosure
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Tax 2026 TCC 62

Brass Collar Capital Corp. v. The King

The Tax Court struck moot portions of Brass Collar’s appeal and parts of an affidavit, holding there was no live tax controversy and no basis to continue.

  • Income tax act
  • Income tax regulations s.306
  • Tax court jurisdiction
  • Mootness doctrine
  • Motion to strike pleadings
  • Affidavit admissibility
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Tax law 2025 FC 2009

Hillcore Financial Corporation v. Canada (Attorney General)

The Federal Court granted Hillcore’s judicial review, finding the CRA Collections Officer made a fresh but unreasonable refusal to refund seized funds, and remitted the matter for redetermination.

  • Garnishment
  • Set-off
  • Refunds
  • Excise tax act
  • Income tax act
  • Judicial review
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Administrative law 2025 FC 1925

Pan v. Canada (Attorney General)

The Federal Court granted judicial review, holding the CRA’s reasons failed to explain why $1,000 remained owing after the applicant says she repaid the CRB amount.

  • Judicial review
  • Reasonableness standard
  • Reconsideration
  • Set-off of benefits
  • Canada recovery benefits act
  • Income tax act
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Tax law 2025 TCC 120

Havilland Holdings Ltd. v. The King

The Tax Court dismissed the Crown’s request to use prior trial transcripts as sworn evidence at a new trial, preferring live testimony for credibility and fairness.

  • Income tax act
  • Partnership losses
  • General anti-avoidance rule (gaar)
  • Admissibility of prior testimony
  • Trial management and reassignment
  • Credibility findings
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Canada decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.