2 total
Motion to consolidate individual and corporate residency appeals granted only for consecutive hearings.
The Minister brought a motion to consolidate seven corporate appeals with one individual appeal to be heard at one trial on common evidence.
The pleadings raise contested issues of residency for both the individual and the corporations.
The Court declined to order full common evidence consolidation, finding that doing so might pre-determine contested evidentiary relevance, but ordered the appeals to be heard one immediately after the other by the same trial judge.
Motion to hold tax appeal in abeyance pending judicial review of MAP request denial dismissed.
The appellant brought a motion to hold his tax appeal in abeyance pending the outcome of an application for judicial review in the Federal Court regarding the denial of a Mutual Agreement Procedure (MAP) request.
The Tax Court of Canada dismissed the motion, finding that the request was premature as the MAP request had already been denied and there was no current issue of double taxation for the years under appeal.
The Court ordered the parties to file a joint request for a timetable to proceed with the appeals.
