Recently, in CIBC World Markets Inc. v. R. (“CIBC case”), the Chief Justice of the Tax Court of Canada (“TCC”) was faced with an issue that was novel to Canada's consumption tax jurisprudence. Can a GST registrant retrospectively change its method for allocating input taxes between its...

In the past two weeks, Senate and House Republicans have put forward parallel mark-up bills in a step toward reform of the U.S. personal and corporate tax systems. The respective bills titled, “Tax Cuts and Jobs Act” (TCJA) are based on previous proposals put forward by Congressional...

In September of 2005, the Canadian government launched a consultation process with regard to the non-taxable status of income trusts. Less than two weeks later, they announced that the issuance of advance rulings with regard to the creation of new income trusts was being suspended. Although...