In this episode of the Friedlan Law Podcast find out about the recent decision of the Federal Court of Appeal in Canada v. Colitto, 2020 FCA 70. The decision of the Federal Court of Appeal overturned the decision of the Tax Court and the victory of the taxpayer. The central question of this case is when an assessment under paragraph 227.1(1) of the Income Tax Act, which relates to directors liability, crystallizes, such that it can give rise to a derivative assessment under Section 160.

In this the first episode of the Friedlan Law Podcast the subject of discussion is the recent case of Eyeball Networks Inc. v. Her Majesty the Queen, 2019 TCC 150, which considers the application of section 160 to a scenario colloquially referred to by tax practitioners as a related party butterfly. In a wide ranging discussion Adam and Phil consider some of the critical issues relating to the case including the wider of significance of the case to the world of tax planning.