TEI’s Canadian Income Tax Committee, in collaboration with a spectacular legal team from Osler, Hoskin & Harcourt LLP, which represented TEI pro bono, recently filed an amicus brief with the Supreme Court of Canada in Deans Knight Income Corporation v. Her Majesty the Queen.
The Deans Knight case addresses important questions regarding the meaning of “control” for purposes of subsection 111(5) of Canada’s Income Tax Act. Oral arguments were held on November 2, and TEI expects a final decision to be rendered approximately nine months after that.
A working group of concerned members developed TEI’s comments under the aegis of TEI’s Canadian Income Tax Committee, chaired by Steve Saunders of ATCO Group. Patrick Evans, TEI chief tax counsel, supported this initiative from the TEI staff.