The case hinged on a small provision in the Income Tax Act, Section 160, which says that if an individual transfers property ...
The King, 2024 FCA 107, dismissing the appeal by the taxpayer and affirming the July 2023 ruling of the Tax Court of Canada. The CRA was allowed to reassess the taxpayer beyond the normal reassessment ...
The UK Supreme Court, by a majority, dismisses HMRC's appeal over a double tax treaty linked to a North Sea oil production ...
The Royal Bank of Canada won’t owe the UK corporation taxes toward payments it received on a North Sea oil production, the ...
The Royal Bank of Canada’s success over HMRC represents a milestone in the interpretation of double tax treaties, Norton Rose ...