Wardlaw v. The Queen, 2019 TCC 199
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2019 TCC 199 |
| Date | 24 September 2019 |
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5 practice notes
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Stone v. The Queen, 2019 TCC 253
...in Rules 4 and 9 of the Tax Court of Canada Rules(General Procedure). [23] However, as I stated in a recent judgment Wardlaw v. HMTQ, 2019 TCC 199, perhaps Parliament may wish to consider the quantum of the penalty, particularly where a loss carryback is [24] The Appellant may wish to obtai......
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Bowker v. The Queen, 2021 TCC 14
...2018 TCC 52. [17] Torres v. The Queen, 2013 TCC 380 at para. 65. [18] Stone v. The Queen, 2019 TCC 253 at para. 24. Wardlaw v. The Queen, 2019 TCC 199 at para. 34. Transcript dated February 12, 2020, testimony of Mrs. Bowker, page 442. [20] Respondent’s Memorandum of Fact and ......
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When CRA Wrongly Denies Input Tax Credits (ITCs) For Businesses That Use Agents: A Canadian GST/HST Tax Trap
...properly drafted written agency agreement. A properly drafted written agency agreement will protect the agent, too. In Anand v The Queen, 2019 TCC 199, for example, a taxpayer provided project-management services to a homeowner who sought to construct a custom-built home. In his capacity as......
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Werstein v. The King, 2023 TCC 64
...losses available for use other taxation years, notwithstanding the greater financial consequences. (See for example, Wardlaw v HMTQ, 2019 TCC 199, paras 11-14.) [3] Wynter v HMTQ, 2017 FCA 195, paras 13 and 16. [4] The Respondent relied on the testimony and evidence of a Canada Revenue Agen......
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3 cases
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Stone v. The Queen, 2019 TCC 253
...in Rules 4 and 9 of the Tax Court of Canada Rules(General Procedure). [23] However, as I stated in a recent judgment Wardlaw v. HMTQ, 2019 TCC 199, perhaps Parliament may wish to consider the quantum of the penalty, particularly where a loss carryback is [24] The Appellant may wish to obtai......
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Bowker v. The Queen, 2021 TCC 14
...2018 TCC 52. [17] Torres v. The Queen, 2013 TCC 380 at para. 65. [18] Stone v. The Queen, 2019 TCC 253 at para. 24. Wardlaw v. The Queen, 2019 TCC 199 at para. 34. Transcript dated February 12, 2020, testimony of Mrs. Bowker, page 442. [20] Respondent’s Memorandum of Fact and ......
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Werstein v. The King, 2023 TCC 64
...losses available for use other taxation years, notwithstanding the greater financial consequences. (See for example, Wardlaw v HMTQ, 2019 TCC 199, paras 11-14.) [3] Wynter v HMTQ, 2017 FCA 195, paras 13 and 16. [4] The Respondent relied on the testimony and evidence of a Canada Revenue Agen......
2 firm's commentaries
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When CRA Wrongly Denies Input Tax Credits (ITCs) For Businesses That Use Agents: A Canadian GST/HST Tax Trap
...properly drafted written agency agreement. A properly drafted written agency agreement will protect the agent, too. In Anand v The Queen, 2019 TCC 199, for example, a taxpayer provided project-management services to a homeowner who sought to construct a custom-built home. In his capacity as......
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CaseNotes For December, 2019
...would have been most likely found to be deductible. 1 The Income Tax Act, RSC 1985, c.1 (5th Supp.), as amended. Wardlaw, A. v. The Queen, 2019 TCC 199- by Dallas In 2009, the Taxpayer attended the Mortgage Centre ("MC") to inquire about a mortgage. MC introduced the Taxpayer to Fiscal Arbi......