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Courses/Law/Tax Law

Current Tax Litigation Insights: Key Court Cases for CPAs

Navigate complex tax law with expert analysis of recent litigation. This course provides crucial insights to shield your clients from pitfalls and optimize their tax strategies.

Created byAJAG Professional Developmentworkspace_premium
4.9
(267 reviews)
BeginnerUpdated Dec 4, 2025
Current Tax Litigation Insights: Key Court Cases for CPAs

What You'll Learn

check_circleAnalyze the CRA's audit powers and unnamed persons requirements.
check_circleGrasp the implications of the Vegi Holding trust dividend case for CPAs.
check_circleUnderstand legal requirements for farm loss deductibility.
check_circleDiscern the factors for deducting foreign tax arrears interest.
check_circleInterpret beneficial ownership in tax treaty contexts.

About This Course

Amit will discuss and critically analyze the year's most important Tax Court and FCA decisions. Accountants and lawyers need to be aware of new and updated principles arising out of the tax jurisprudence. Given the importance of the cases and the evolving nature of the law, it is incumbent upon professionals to know what has been updated, modified, changed, or in some cases, totally overruled. He will address all of this in the presentation. Specific topic areas will include: updates to the GAAR, section 160 assessments revisited, the Court's views on loss-trading, shareholder benefits.

The most important cases discussed are:

  • Shopify: Understanding the limits of CRA's audit powers and unnamed persons requirements, particularly in the digital economy. Learn when the CRA oversteps and how to challenge overly broad information requests.
  • VEGHI Holding: Navigating the complexities of trust dividends and deeming provisions. This Federal Court of Appeal decision clarifies the timing of connection for Part IV tax purposes, crucial for corporate tax planning involving trusts.
  • ACWABOA & Stackhouse: Key lessons on taxpayer responsibilities regarding address updates and the pitfalls of farm loss deductions. Understand the importance of clear communication with the CRA and the commerciality requirements for business losses.
  • Senecchi: A deep dive into the "reasonable expectation of profit" test within the context of side businesses and network marketing. Discover what courts consider a legitimate business endeavor and the significance of credible record-keeping.
  • BMO: Examining the deductibility of interest on foreign tax arrears. This ruling offers critical guidance for businesses with cross-border operations, differentiating between arrears interest and refund interest.
  • Husky Energy: Exploring beneficial ownership in the context of tax treaties and dividend withholding tax. Understand the judicial scrutiny applied to arrangements designed to minimize tax liabilities through interposing entities.

By analyzing these landmark cases, you will enhance your ability to advise clients effectively, anticipate potential tax challenges, and navigate the intricacies of the Canadian tax system. This course is indispensable for CPAs seeking to sharpen their litigation awareness and maintain a competitive edge in today's dynamic tax landscape.

This course is ideal for: All Practitioners

Your Instructors

AJAG Professional Development
AJAG Professional Development
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star8,743 reviews

AJAG Professional Development was founded in 2003 with a mission of making professional development easier and more cost-effective for Canadian accountants and other financial advisory professionals. Our comprehensive range of flexible and reasonably-priced courses, programs and seminars are delivered online and in classroom-style settings in the Greater Toronto Area (Toronto, Oakville and Markham). AJAG features a roster of highly-qualified instructors who deliver content that is pertinent, up-to-date and engaging.

Amit  Ummat LL.B LL.M
Amit Ummat LL.B LL.M

Partner at Miller Thomson LLP

Amit Ummat specializes in income tax and GST/HST litigation across a broad range of industries. He delivers strategic advice and representation in tax disputes, including appearances before all Canadian courts. Amit is skilled in managing audits, negotiating with tax authorities, and securing favorable settlements for his clients. His practice also encompasses international tax controversy, and his legal writing on complex tax issues is internationally recognized. Throughout his career, Amit has successfully litigated a wide range of tax disputes, securing favorable outcomes for clients on matters including capital versus income characterization, interest deductibility, transfer pricing, and shareholder benefits. He holds a tax-focused LL.M. and is certified by the Law Society of Ontario as a Specialist in Taxation Law. Amit is actively involved in the broader tax community, frequently speaking at both tax and non-tax conferences on a range of tax issues. He is a regular presenter for the Canadian Tax Foundation, delivers courses for accountants and tax lawyers, and contributes to a wide array of professional publications.

Credit Information

Is this course eligible for my CPD requirements as a Canadian CPA?

Provincial regulators of CPAs in Canada do not require that independent providers of CPD be approved to offer courses. Instead, individual CPAs are responsible for assessing whether a CPD activity meets their requirements, and may take activities from any source provided those requirements are met.

Every course offered on LearnFormula is delivered by a qualified subject matter expert or learning organization, and advances learning objectives that are relevant to the responsibilities or professional competencies of Canadian CPAs. All activities on LearnFormula are quantifiable in terms of hours, and are also verifiable, in that users receive documented evidence of their attendance via a certificate of completion after finishing a course (and this certificate is stored by LearnFormula indefinitely). Nearly 100,000 Canadian CPAs successfully satisfy their CPD requirements via LearnFormula on an annual basis.

What Students Are Saying

4.9
Student's Choice
267 reviews

Frequently Asked Questions

We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.