Feigenbaum Law

recent decisions

Legal fees

Tax Disputes & Litigation

Cameco Awarded More than $10 Million in Legal Fees After Decade Long Dispute with the CRA

Canadian resource company Cameco, one of the world’s largest producers of uranium fuel, recently announced that it would be receiving $10.25 million in costs after a protracted battle with the Canada Revenue Agency (CRA) over alleged tax evasion. Some Background The dispute began when the CRA questioned Cameco’s corporate structure following the company’s reorganization in the late 1990’s. At issue was whether Cameco used a Swiss subsidiary, Cameco Europe Ltd. (CEL) as a means of… Read More

Offshore

Litigation

CRA Brings Loblaws to Court Claiming Offshore Corporate Tax-Avoidance

Proceedings between Loblaw Companies Ltd. (Loblaws) and the Canada Revenue Agency (CRA) began earlier this week in Tax Court. The CRA claims that Loblaws’ banking subsidiary has been used as part of a tax avoidance scheme. Depending on the outcome of the case, Loblaws may be liable for more than $400 million. The Details The CRA is alleging that Loblaws established Glenhuron Bank Ltd. (Glenhuron), a “phoney” bank in Barbados, in order to circumvent the… Read More

Condos

Corporate Tax Planning

Current Developments Affecting The Foreign Bank Reporting Form (FBAR) And Filing Requirements

An interesting tax case regarding the Foreign Bank Accounts Reporting Form (FBAR) and the associated penalty for non-filing has been prominent in the news recently. The Report of Foreign Bank and Financial Accounts filing requirement was introduced by the Currency and Foreign Transactions Reporting Act of 1970, also identified as the Bank Secrecy Act (Title 31 of the United States Code). The purpose of the requirement is to obtain information that would be useful in… Read More