Information About Building NewLaw Podcast

Key Takeaways The result was fixed before Chobham Corporation Ltd. filed its Notice of Appeal. In many cases, the Tax Court can overturn a reassessment; this was not that kind of case. Internal agreement that a reassessment is unfair feels like a winning argument. It isn’t. The Trust’s whole case wa … Read more »

A tax opinion answers a narrower question than most readers assume. Some of the limits are written into the document — in its assumptions, its scope section, its definitions paragraph, and its date. These are the parts read least. Nothing in the opinion, or in the file behind it, records who supplie … Read more »

 A tax plan is moving toward implementation. The tax opinion has been delivered.  The first question is whether the filing position is defensible. A tax opinion may answer that question and stop there. However, a conclusion that a filing position is defensible does not necessarily address how the po … Read more »

A company receives a CRA reassessment after prior planning work and tax opinions supported the transactions or filing positions. The company believes the core risk has already been addressed. The original filing position was reviewed. The company obtained the opinion. The company filed accordingly. … Read more »

Key Takeaways The decisive failure in Zhang v. HMK was not mechanical. The CRA lost control of its ability to change the outcome after it accepted a settlement proposal. The taxpayer preserved flexibility by controlling the operative record. The case exposed a recurring institutional dynamic inside … Read more »