Canadian Court Upholds JP Morgan Request For Review of CRA’s Discretion to Reassess

OTTAWA—The Federal Court of Canada has upheld an application by JP Morgan Asset Management (Canada) Inc. to review the Canada Revenue Agency’s use of its discretion in a case involving deductibility of fees paid to the company’s U.S. parent and overseas sister companies. [JP Morgan Asset Management (Canada) Inc. v. Minister of National Revenue]

In the May 28 ruling, made public July 5, Case Management Judge Kevin R. Aalto said there are “significant and controversial” issues between JP Morgan and the CRA over the use of discretion in conducting and issuing reassessments. Thus, he rejected the government’s argument ...