The Federal Court of Appeal has dismissed the taxpayer’s appeal in Labow v R, 2011 FCA 305. The taxpayer had paid amounts to an offshore health and welfare trust for his wife`s benefit (she was an employee in his surgical practice). The CRA reassessed beyond the normal limitation period to deny the deduction for the payments and attribute to the taxpayer income earned by the offshore trust. The Tax Court dismissed the taxpayer`s appeal, which result was upheld by the Federal Court of Appeal.
▼
▲
