Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Court of Appeal (Canada) |
| Citation | 2019 FCA 67 |
| Date | 03 April 2019 |
-
- This document is available in original version only for vLex customers
View this document and try vLex for 7 days - TRY VLEX
- This document is available in original version only for vLex customers
43 practice notes
-
Canada (National Revenue) v. Zeifmans LLP, 2023 FC 1000
...and lie at the heart of the Minister’s ability to enforce taxation legislation: Canada (National Revenue) v Cameco Corporation, 2019 FCA 67 at para 27; Roofmart Ontario Inc v Canada (National Revenue), 2020 FCA 85 at para 55 [Roofmart]. Subsection 231.2(1) confers broad and general p......
-
Ghermezian v. Canada (Attorney General), 2020 FC 1137
...is entitled to pursue a process of “poke-and-check” (language recently employed in Canada (National Revenue) v Cameco Corporation, 2019 FCA 67 [Cameco] at para 43) in its efforts to verify a person’s compliance with the ITA. In eBay, the Federal Court of Appeal described the Minister’s powe......
-
Pierre v. Canada (Public Safety and Emergency Preparedness), 2020 FC 887
...appear before the Court with the best of good faith and propriety (Baron at para 65). In Canada (National Revenue) v Cameco Corporation, 2019 FCA 67 [Cameco], the Federal Court of Appeal recently reiterated that the “clean hands” doctrine is “an equitable doctrine, under which a party may b......
-
Surmanidze v. Canada (Public Safety and Emergency Preparedness), 2019 FC 1615
...v Canada (Public Safety and Emergency Preparedness), 2019 CanLII 36998 (FC ). [31] In Canada (National Revenue) v Cameco Corporation, 2019 FCA 67, the Federal Court of Appeal recently clarified at para 37 that “for past conduct to justify a refusal of relief, the conduct must relate directl......
Request a trial to view additional results
23 cases
-
Canada (National Revenue) v. Zeifmans LLP, 2023 FC 1000
...and lie at the heart of the Minister’s ability to enforce taxation legislation: Canada (National Revenue) v Cameco Corporation, 2019 FCA 67 at para 27; Roofmart Ontario Inc v Canada (National Revenue), 2020 FCA 85 at para 55 [Roofmart]. Subsection 231.2(1) confers broad and general p......
-
Ghermezian v. Canada (Attorney General), 2020 FC 1137
...is entitled to pursue a process of “poke-and-check” (language recently employed in Canada (National Revenue) v Cameco Corporation, 2019 FCA 67 [Cameco] at para 43) in its efforts to verify a person’s compliance with the ITA. In eBay, the Federal Court of Appeal described the Minister’s powe......
-
Pierre v. Canada (Public Safety and Emergency Preparedness), 2020 FC 887
...appear before the Court with the best of good faith and propriety (Baron at para 65). In Canada (National Revenue) v Cameco Corporation, 2019 FCA 67 [Cameco], the Federal Court of Appeal recently reiterated that the “clean hands” doctrine is “an equitable doctrine, under which a party may b......
-
Surmanidze v. Canada (Public Safety and Emergency Preparedness), 2019 FC 1615
...v Canada (Public Safety and Emergency Preparedness), 2019 CanLII 36998 (FC ). [31] In Canada (National Revenue) v Cameco Corporation, 2019 FCA 67, the Federal Court of Appeal recently clarified at para 37 that “for past conduct to justify a refusal of relief, the conduct must relate directl......
Request a trial to view additional results
20 firm's commentaries
-
2021 Federal Budget – Selected Tax Measures
...dispute regarding the application of the transfer pricing rules, the government recently lost a decision in Canada v. Cameco Corporation, 2019 FCA 67, which called into question the extent to which CRA officials can require a corporate taxpayer to make employees available to submit to oral ......
-
Scope Of Canada Revenue Agency Audit Powers Limited By Recent FCA Decision. The CRA Response Raises New & Different Risks For Taxpayers
...not compel employees of a taxpayer to attend interviews to answer oral questions as part of an audit. In Canada v. Cameco Corporation, 2019 FCA 67, the CRA sought a compliance order under subsection 231.7(1) of the Income Tax Act to required employees of Cameco to attend oral interviews. Ca......
-
Budget 2021: CRA To Be Granted The Authority To Compel Oral Responses
...to the audit authority of the CRA will take effect upon their enactment. Footnote 1 Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67 available online The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions ......
-
Canadian Cryptocurrency Tax Trap: Poor Record-Keeping Will Leave You At The CRA's Mercy: Record-Keeping Requirements For Canadian Cryptocurrency Traders & Investors ' Canadian Tax Guidance From A Canadian Tax Lawyer
...the Canada Revenue Agency "does not have the power to compel a taxpayer to answer questions at the audit stage": MNR v Cameco Corporation, 2019 FCA 67, at para 28. (The 2021 federal budget proposed to override the Cameco decision by amending section 231.1 of Canada's Income Tax Act. The pro......
Request a trial to view additional results