INTRODUCTION
The last year has provided no shortage of exciting and
interesting tax cases that tax practitioners can learn from.
Accordingly, the purpose of this paper is to review a select number
of cases that we felt were important to highlight. Each case begins
with a short summary followed by the facts, judicial reasoning and
the take-away message.
SWIRSKY1
Summary
Owner-manager remuneration is important to many businesses,
especially family businesses. Swirsky emphasizes the importance of
distinguishing between different forms of owner-manager
remuneration in certain circumstances. In a nutshell, this case
involves a question of interest deductibility wherein the Federal
Court of Appeal held that interest was not deductible as the shares
were not acquired to earn income.
