Session starts in:
This session is included with your CTM membership.
105 minutes of teaching plus 15 minutes of live Q&A discussion.
The webinar recording will be available shortly following the live event.
Includes tax tables, worked examples, planning notes, technical references, and supporting resource materials.
A CPD certificate is available after successful quiz completion.
A taxpayer paid roughly $6,000 to fund another person’s Federal Court of Appeal tax appeal, then claimed $6,211 on her own return. Paragraph 60(o) restricts who pays and what the fees must relate to, but says nothing expressly about whose assessment must be in dispute. CRA denied the claim, upheld that denial through objection, and she took the issue to General Procedure.
The facts are narrow — one person paid another's tax-dispute fees. The reasoning is not.
The words favoured the taxpayer and she still lost. Context and purpose can displace a reading that looks unambiguous, which makes the plain words the start of the analysis rather than the end of it.
A principle repeated for twenty years in an Informal Procedure decision that also turned on a second, independent ground. Checking what a case rests on is part of relying on it.
Legislative purpose does not replace the words, but it can change how those words are understood. Finding the problem Parliament was trying to solve can explain why an apparently straightforward reading does not survive the full analysis.
Tax Authority
FCPA, FCA, TEP
TAX STRATEGY & OPTIMIZATION
CPA, CA
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You'll receive a confirmation email for your registration, along with a link to access the live session.
If you cannot attend live, the recording will be made available in your CTM account shortly after the session ends, so you can watch on demand.
Yes. The detailed slide deck and supporting materials will be posted shortly before the live session. When the recording is available, you'll be notified by email.
You can access this session and its materials through your CTM account for as long as your CTM membership is active.
Yes. A CPD certificate is available after successful quiz completion.
Yes. We will take questions during the live Q&A portion after the teaching session.
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This session is included with your CTM membership, along with the full member library.
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