Laurent Bartleman

The appellant brought a motion to strike portions of the respondent's Replies regarding transfer pricing adjustments for the 2007-2015 taxation years, arguing failure to disclose arm's length terms and issue estoppel based on prior litigation.

The Tax Court dismissed the motion to strike and the request for judgment under Rule 170.1, but ordered the respondent to provide particulars regarding the arm's length prices and terms relied upon.

The appellant appealed a reassessment for the 2015 taxation year.

The parties reached a settlement agreement to refer the reassessment back to the Minister, but the appellant died before signing the amended consent to judgment.

The Crown argued it could no longer settle due to the lack of an executor.

The Tax Court enforced the settlement agreement, amended the style of cause to reflect the estate, and allowed the appeal in accordance with the agreed terms.

The plaintiff sought the Court's approval to discontinue her proposed class proceeding against the Attorney General of Canada regarding the interpretation of "self-employment income" under the Canada Emergency Response Benefit Act.

The Court approved the discontinuance without costs, finding that the proposed class members would not be prejudiced because a recent Remission Order relieved individuals from repaying the CERB if they had applied based on gross rather than net self-employment income.