Margaret Nixon

Margaret Nixon Partner

Representative Work
  • A manufacturer in an application in the Federal Court by the Canada Revenue Agency for an order compelling the production of a tax planning document pursuant to section 231.1 of the Income Tax Act.
  • A company in the packaging industry in an appeal to the Federal Court of Appeal involving the characterization of a gain on a disposition of shares as being on income or capital account.
  • An environmental services provider in an appeal to the Tax Court of Canada involving the deductibility of transaction expenses.
  • An energy company in Notices of Objection to reassessments by the Canada Revenue Agency involving Regulation 105 withholding tax.
  • A manufacturer in an audit by the Canada Revenue Agency involving proposed transfer pricing adjustments and penalties relating to interest deductibility and the fair market value of shares.
  • A non-resident corporation in an appeal to the Tax Court of Canada involving beneficial ownership, residency and the application of the general anti-avoidance rule to dividends subject to Part XIII withholding tax.
  • A corporation in the foodservice industry in a Notice of Objection to a reassessment by the Canada Revenue Agency involving a disposition of eligible capital property.
  • An investment dealer in a matter involving a requirement for information and documents issued by the Canada Revenue Agency pursuant to section 231.2 of the Income Tax Act.
  • A manufacturer in the Superior Court of Justice (Ontario) in a collection matter involving the Canada Revenue Agency’s withholding of goods and services tax and provincial sales tax refunds.
  • A Canadian corporation in a Notice of Objection to a reassessment by the Canada Revenue Agency involving the application of subsection 55(2) to dividends paid prior to a share sale.
  • A limited partner of a partnership in an audit by the Canada Revenue Agency involving partnership distributions and deemed capital gains.
  • A multinational insurance company in Notices of Objection to reassessments by the Canada Revenue Agency involving charitable donation tax credits.
  • A Canadian-resident individual in an audit by the Canada Revenue Agency involving distributions from a non-resident trust.
  • A Canadian corporation in an appeal to the Tax Court of Canada involving the fair market value of shares transferred as part of a court-approved plan of arrangement.
  • A manufacturer in an appeal to the Federal Court of Appeal involving the application of the general anti-avoidance rule to repayments of capital that were recharacterized as dividends and subject to Part XIII withholding tax.
  • A Canadian consumer products distributor in a matter involving transfer pricing adjustments and penalties.
  • A technology company in a matter involving the application of the “bump” rules.
  • A company in the healthcare services industry in an appeal to the Superior Court of Justice (Ontario) involving a determination of the existence of separate businesses.
  • A corporation engaged in the manufacturing and retailing of apparel in an audit by the Canada Revenue Agency involving proposed transfer pricing penalties.
  • A property and casualty insurance company in an appeal to the Tax Court of Canada involving deemed proceeds of disposition pursuant to subsection 55(2) of the Income Tax Act.
  • An insurance corporation in an appeal to the Tax Court of Canada involving an election deeming it to be a “non-resident-owned investment corporation” for the purposes of obtaining a refundable tax following an amalgamation.
  • A private investment corporation in an appeal to the Tax Court of Canada involving the application of the surrogatum principle to a settlement payment.
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