Deyab v. Canada, 2020 FCA 222
By Sambif
Chapters
- Introduction0 concepts
- Deyab v. Canada, 2020 FCA 2220 concepts
- I. Background3 concepts
- II. Decision of the Tax Court3 concepts
- III. Issues and Standard of Review2 concepts
- IV.
Analysis0 concepts
- — IV. Analysis1 concept
- — A. Burden of Proof4 concepts
- — B. Adverse Inference3 concepts
- — C.
The Application of Lacroix0 concepts
- — — C. The Application of Lacroix1 concept
- — — (1) The Decisions of this Court and the Tax Court in Lacroix3 concepts
- — — (2) Gross Negligence Penalties versus Reassessing a Statute-barred Year3 concepts
- — — (3) The Tax Court Judge’s Errors2 concepts
- — — (4) Should the Assessment of the Gross Negligence Penalties be Confirmed?2 concepts
- V. Conclusion1 concept
- News of Note0 concepts
- News of Note0 concepts
- — News of Note1 concept
- — Nuvei v. Arrap - NSW Supreme Court finds that a post-closing voluntary disclosure by the target so as to deplete escrowed funds did not violate a duty to cooperate with the vendor3 concepts
- — CRA comments on a s. 17(1) inclusion under a s. 17(2) B2B loan and the partially offsetting FAPI deduction under s. 17(1) – B(c)3 concepts
- — Income Tax Severed Letters 14 October 20261 concept
- — CRA restricts taxpayer requests to revise permissive deductions3 concepts
- — CRA updates its SR&ED ITC policy2 concepts
- — CRA expands its FAQ webpage on bare trust reporting3 concepts
- — A post-spinoff amalgamation may taint the spin-off2 concepts
- — CRA finds that an indemnity given by a Canadian NRT beneficiary regarding a trust distribution received from the trustee did not cause s. 94(2)(d) to apply1 concept
- — CRA confirms that CUEC computed in the first (EIFEL) regime year using a 40% ratio must for carryforward purposes be recomputed using the 30% ratio1 concept
- — Income Tax Severed Letters 7 October 20261 concept
- — Pages1 concept
- CRA Publications0 concepts
- CRA Publications3 concepts
- Words and Phrases0 concepts
- Conferences/Reports/Letters0 concepts
- Conferences/Reports/Letters8 concepts
- Subscribe to Tax Interpretations0 concepts
- Subscribe to Tax Interpretations0 concepts