Canada v. CBS Canada Holdings Co., 2020 FCA 4
| Court | Federal Court of Appeal (Canada) |
| Case Date | January 10, 2020 |
| Jurisdiction | Canada (Federal) |
| Citations | 2020 FCA 4 |
-
- 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
6 practice notes
-
Husky Energy Inc. v. The King, 2023 TCC 167
...the tax rate under Article X of the Barbados Treaty. [205] R. v. Last, 2014 FCA 129 at paragraph 23 and R. v. CBS Canada Holdings Co., 2020 FCA 4 paragraphs 40 to [206] See, also, Alta Energy at paragraphs 40, 41, 43 and 84. [207] 2009 FCA 57 at paragraphs 13 and 14. [208] Ibid., paragr......
-
Glofish LLC v. Oceanview Enterprise,
...and is one that can legally be granted. [12] The principles laid out in Galway were recently reiterated in Canada v CBS Canada Holdings Co, 2020 FCA 4 at paragraphs 29–30. [13] Thus, I must satisfy myself that I have jurisdiction to issue the order sought by the parties. B. Can Juris......
-
Canada's Top Court Decides Against Equitable Rescission In Collins Family Trust
...that settlement agreements reached between taxpayers and the Minister are valid and binding on both parties (see Canada v CBS Holdings Co., 2020 FCA 4). One must hope that the rather inopportune language by the Supreme Court at paragraphs 25 and 26 of Collins will not lead to a reconsiderat......
-
Supreme Court To Consider Tax Court Jurisdiction
...FC and TCC please see, 1594418 Ontario Inc. v. Minister of National Revenue, 2021 FC 157; Her Majesty the Queen v. CBS Canada Holdings Co., 2020 FCA 4; and Westminster Savings Credit Union v. Canada (Attorney General), 2019 FC About BLG The content of this article is intended to provide a g......
Request a trial to view additional results
1 cases
-
Glofish LLC v. Oceanview Enterprise,
...and is one that can legally be granted. [12] The principles laid out in Galway were recently reiterated in Canada v CBS Canada Holdings Co, 2020 FCA 4 at paragraphs 29–30. [13] Thus, I must satisfy myself that I have jurisdiction to issue the order sought by the parties. B. Can Juris......
4 firm's commentaries
-
Canada's Top Court Decides Against Equitable Rescission In Collins Family Trust
...that settlement agreements reached between taxpayers and the Minister are valid and binding on both parties (see Canada v CBS Holdings Co., 2020 FCA 4). One must hope that the rather inopportune language by the Supreme Court at paragraphs 25 and 26 of Collins will not lead to a reconsiderat......
-
Supreme Court To Consider Tax Court Jurisdiction
...FC and TCC please see, 1594418 Ontario Inc. v. Minister of National Revenue, 2021 FC 157; Her Majesty the Queen v. CBS Canada Holdings Co., 2020 FCA 4; and Westminster Savings Credit Union v. Canada (Attorney General), 2019 FC About BLG The content of this article is intended to provide a g......
-
Crown Bound By Settlement Agreement To Allow Losses It Claimed To Be A Fiction
...the recent decision Her Majesty the Queen v. CBS Canada Holdings Co., 2020 FCA 4, the Federal Court of Appeal held that the Crown (i.e., Her Majesty the Queen, representing the Minister of National Revenue and her agent the Canada Revenue Agency) could not resile from a settlement agreement......
-
Federal Court Of Appeal Blocks Crown From Reneging On Tax Settlement
...there is probably no reason to confuse a Court with unnecessary or extraneous details. Footnotes 1 The Queen v CBS Canada Holdings Co, 2020 FCA 4 ("CBS 2 The "principled basis" means that a tax appeal must be resolved in accordance with the facts and law, rather than on the basis of a pure ......