What tax practitioner hasn’t woken up in the middle of the night, sweating, because of dreams haunted by section 84.1 file demons? I will try to banish the demons — or propitiate them anyway — in a short presentation on February 2, 2006 at the CRA’s Hamilton & District Tax Consultation Group.
Here are links to some of the resources I cite in the presentation that can be found on-line:
- The Queen v. Olsen, 2002 FCA 3
- IT-419R2 “Meaning of Arm’s Length”
- Brouillette v. The Queen, 2005 TCC 203
