A Canadian telecommunications corporation was reassessed by the Canada Revenue Agency under the federal Income Tax Act to include more than $500 million in computing its income based on the application of the Foreign Accrual Property Income rules to a complex series of transactions. This reassessment made the client liable for over $240 million in tax, interest, and penalties.
In a team led by Jenny Mboutsiadis, which included Ronald Nobrega and Vaso Maric, Fasken successfully acted on this tax litigation mandate and prepared and submitted a comprehensive objection to the reassessment to the Canada Revenue Agency’s Appeals Division. Based on Fasken’s written submissions alone, the Canada Revenue Agency reduced the reassessed income from over $500 million to less than $20 million, representing a 96% reduction in taxable income and a corresponding reduction in tax, interest, and penalty liabilities.
Jurisdiction
- Canada
