Feigenbaum Law

tax litigation

Appeal

Tax Disputes & Litigation

Mark Feigenbaum Files Appeal to the U.S. Supreme Court in High-Stakes Cross-Border Tax Issue

Our offices have recently filed a Writ of Certiorari, a request to appeal to the United States Supreme Court, asking that court to review lower court level decisions made with respect to a client who had significant IRS penalties levied against him. What Happened? Our client, an American who has lived in Canada since the 1970’s, had not filed any income tax statements in the U.S. since his relocation north of the border. The man… Read More

Audit

Litigation

CRA Ordered to Pay $5 Million After “Unreasonable” Audit

The Canada Revenue Agency (CRA) was recently ordered to pay damages of almost $5 million after two men representing a group of taxpayers sued the agency claiming that the CRA engaged in “abusive” practices during an offshore tax audit which the men were caught up in. In a lengthy decision supporting the damages order, the Quebec Superior Court admonished the CRA for a number of questionable practices that took place during the… 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