Paletta v. The Queen, 2019 TCC 205
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Date | 05 April 2022 |
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5 practice notes
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Paletta Estate v. The Queen, 2021 TCC 11
...it was in final argument), it deserves some analysis. [211] The two most recent decisions of this Court on sham are Paletta v The Queen, 2019 TCC 205 and Agracity Ltd. v The Queen, 2020 TCC 91 . In Paletta, Justice Hogan described the governing principles (citations omitted): [121] There a......
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Why Is The CRA Targeting Temporary Labour Agencies?
...of accommodation" scheme? The legal tests for sham transactions and "invoices of accommodation" are similar. In Paletta v The Queen, 2019 TCC 205, the Tax Court of Canada (the "Tax Court") stated that sham requires an element of misrepresentation of the actual transaction, as well as an ele......
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Federal Court Of Appeal Rules Sham Need Not Be Specifically Plead
...2021, the Federal Court of Appeal (FCA) dismissed the Taxpayers' appeal from the Tax Court of Canada's decision in Paletta v The Queen, 2019 TCC 205 The primary issue under appeal was whether breaches of procedural fairness tainted the Tax Court hearing. Critically, the Taxpayers submitted ......
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Federal Court Of Appeal Rules Sham Need Not Be Specifically Plead
...2021, the Federal Court of Appeal (FCA) dismissed the Taxpayers' appeal from the Tax Court of Canada's decision in Paletta v The Queen, 2019 TCC 205 The primary issue under appeal was whether breaches of procedural fairness tainted the Tax Court hearing. Critically, the Taxpayers submitted ......
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2 cases
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Paletta Estate v. The Queen, 2021 TCC 11
...it was in final argument), it deserves some analysis. [211] The two most recent decisions of this Court on sham are Paletta v The Queen, 2019 TCC 205 and Agracity Ltd. v The Queen, 2020 TCC 91 . In Paletta, Justice Hogan described the governing principles (citations omitted): [121] There a......
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Billy Liang v. The Queen, 2022 TCC 55
...the Court with his written arguments by May 4th. He did so. [2] Canada v. Baxter, 2007 FCA 172. [3] Paletta v. The Queen, 2019 TCC 205. [4] In reality, the risk was zero since there has been no loss whatsoever since Pony was incorporated. [5] That never happened. No movie what......
3 firm's commentaries
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Why Is The CRA Targeting Temporary Labour Agencies?
...of accommodation" scheme? The legal tests for sham transactions and "invoices of accommodation" are similar. In Paletta v The Queen, 2019 TCC 205, the Tax Court of Canada (the "Tax Court") stated that sham requires an element of misrepresentation of the actual transaction, as well as an ele......
-
Federal Court Of Appeal Rules Sham Need Not Be Specifically Plead
...2021, the Federal Court of Appeal (FCA) dismissed the Taxpayers' appeal from the Tax Court of Canada's decision in Paletta v The Queen, 2019 TCC 205 The primary issue under appeal was whether breaches of procedural fairness tainted the Tax Court hearing. Critically, the Taxpayers submitted ......
-
Federal Court Of Appeal Rules Sham Need Not Be Specifically Plead
...2021, the Federal Court of Appeal (FCA) dismissed the Taxpayers' appeal from the Tax Court of Canada's decision in Paletta v The Queen, 2019 TCC 205 The primary issue under appeal was whether breaches of procedural fairness tainted the Tax Court hearing. Critically, the Taxpayers submitted ......