Bennett Jones on Tax Disputes - September 2020

September 03, 2020

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The 10th edition of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters, includes articles on the possible application of section 160.1 of the Income Tax Act (Canada) which permits the Minister of National Revenue to recover excessive refunds in certain circumstances, the Federal Court of Appeal decision in Cameco Corporation and discusses the decision's impact on the application of the recharacterization rules in the Canadian transfer pricing regime, and the recent case of Andersen v. The Queen, 2020 TCC 51, which turned on the burden of proof and CRA's duty to properly plead its case against the taxpayers. The publication also has summaries of recent tax decisions, tables regarding tax appeals, the CRA business continuity plans and bulletins/practice directives from the courts.

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