Superior Plus Corp. v. The Queen, 2016 TCC 217

JurisdictionFederal Jurisdiction (Canada)
Subject MatterEVIDENCE,PRACTICE
Citation2016 TCC 217
CourtTax Court (Canada)
Date29 September 2016
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6 practice notes
  • CANADIAN WESTERN TRUST COMPANY AS TRUSTEE OF THE FAREED AHAMED TFSA v. HER MAJESTY THE QUEEN, 2020 FCA 213
    • Canada
    • Court of Appeal (Canada)
    • December 10, 2020
    ...[21] The Tax Court based its finding that the internal documents in question are of marginal relevance on Superior Plus Corp. v. Canada, 2016 TCC 217 at para. 34, which provides such documents are not relevant to ascertaining the Minister’s mental process in auditing and assessing a taxpaye......
  • Canada v. CHR Investment Corporation, 2021 FCA 68
    • Canada
    • Court of Appeal (Canada)
    • April 9, 2021
    ...or the CRA have not been upheld. In a subsequent decision involving a refusal to answer questions in the Superior Plus Corp. matter (2016 TCC 217), the Tax Court refused to compel the Crown to respond to questions related to opinions expressed by officials working with the Department of Fin......
  • LBL Holdings Limited v. The Queen, 2018 TCC 63
    • Canada
    • Tax Court (Canada)
    • March 27, 2018
    ...Alberta For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada [1] 2015 TCC 115. [2] 2015 TCC 280. [3] 2016 TCC 217. [4] 2015 TCC 14. [5] Paletta v. The Queen, 2017 TCC 233. [6] My understanding is that these stores were operated by various members of the Ma......
  • CHR Investment Corporation v. The Queen, 2020 TCC 17
    • Canada
    • Tax Court (Canada)
    • January 30, 2020
    ...of the current taxpayer or had been considered by officials involved in the audit (para. 8, Superior). [11] In Superior Plus Corp. v. R., 2016 TCC 217 (general procedure), this Court per Hogan, J. determined that views of the federal Department of Finance as to policy underlying the federal......
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6 cases
  • CANADIAN WESTERN TRUST COMPANY AS TRUSTEE OF THE FAREED AHAMED TFSA v. HER MAJESTY THE QUEEN, 2020 FCA 213
    • Canada
    • Court of Appeal (Canada)
    • December 10, 2020
    ...[21] The Tax Court based its finding that the internal documents in question are of marginal relevance on Superior Plus Corp. v. Canada, 2016 TCC 217 at para. 34, which provides such documents are not relevant to ascertaining the Minister’s mental process in auditing and assessing a taxpaye......
  • Canada v. CHR Investment Corporation, 2021 FCA 68
    • Canada
    • Court of Appeal (Canada)
    • April 9, 2021
    ...or the CRA have not been upheld. In a subsequent decision involving a refusal to answer questions in the Superior Plus Corp. matter (2016 TCC 217), the Tax Court refused to compel the Crown to respond to questions related to opinions expressed by officials working with the Department of Fin......
  • LBL Holdings Limited v. The Queen, 2018 TCC 63
    • Canada
    • Tax Court (Canada)
    • March 27, 2018
    ...Alberta For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada [1] 2015 TCC 115. [2] 2015 TCC 280. [3] 2016 TCC 217. [4] 2015 TCC 14. [5] Paletta v. The Queen, 2017 TCC 233. [6] My understanding is that these stores were operated by various members of the Ma......
  • Fareed Ahamed TFSA v. The Queen, 2019 TCC 121
    • Canada
    • Canada (Federal) Tax Court (Canada)
    • May 24, 2019
    ...threshold has been repeatedly and clearly enunciated by the Courts in various decisions, most recently in Superior Plus Corp. v. Canada, 2016 TCC 217 by Hogan J. at paragraph 34, relied upon by MP Properties and Total Energy Services Inc. v. Canada, 2019 TCC 112, amongst others: [34] As dis......
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