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Focus on Tax - Knights of Columbus
Author(s): Bissell, Brendan, Chua, Chia-yi, Innes, William, Peters, Matthew
Date:  June 24 2008
On Friday June 13, 2008, multinational enterprises doing business in Canada finally received greater tax certainty in respect of their cross-border operations. On that day, the Crown informed the Knights of Columbus that the government would not appeal the Tax Court decision in Knights of Columbus v. R. (2008 D.T.C. 3648), a ground-breaking case that had established a precedent for the definition of "permanent establishment" under the Canada-U.S. tax treaty.

This was a significant victory for the Knights of Columbus for two reasons: first, the Tax Court found that the Knights did not have a "permanent establishment" under the treaty and was not taxable on its insurance operations in Canada; second, the Knights and its Fraser Milner Casgrain LLP (FMC) tax litigation counsel – Bill Innes, Chia-yi Chua, and Brendan Bissell – went from Notice of Appeal to court judgment in only 378 days.

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