Jared Mackey, Derrick Hosanna and Allyson Cairns-Walji authored "B.C. Court of Appeal Gives New Life to Post-Fairmont Rectification" in
Bennett Jones on Tax Disputes, Issue 5, published by Thomson Reuters.
In 5551928 Manitoba Ltd v Canada (Attorney General), the B.C. Court of Appeal allowed the rectification of a tax mistake, saving the corporate taxpayer from a punitive 60% tax. The decision highlights the ongoing uncertainty regarding how the narrow test for rectification established by the Supreme Court of Canada in Fairmont Hotels will be applied by Canadian Courts.
Bennett Jones