Davies partner Neal Armstrong has been recognized as an Indirect Tax Leader: Canada in the International Tax Review’s 2018 Indirect Tax Leaders guide.
Neal has over 30 years of experience in domestic and international tax matters, with particular expertise in REITs, GST/HST, financings, and inbound and outbound cross-border transactions. He is the editor of Tax Interpretations, an online commentary on the transactional implications of a broad range of Canadian tax matters. In 2016, Neal acted for RioCan Real Estate Investment Trust on Canadian and U.S. tax matters in connection with the US$1.9-billion sale of its portfolio of 49 shopping centres to Blackstone Real Estate Partners.
Published annually, the Indirect Tax Leaders guide lists the world’s leading indirect tax practitioners, as identified via peer nominations and recommendations.
Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt
Dec. 04, 2024 - The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments increase taxable income that is offset by the carryback of a loss...
U.S. Supreme Court Upends 40 Years of Judicial Deference to Regulations
July 25, 2024 - In a historical opinion in Loper Bright Enterprises v. Raimondo, Secretary of Commerce, released at the end of June, the U.S. Supreme Court overturned the “Chevron” doctrine, which for so long had controlled judicial review of U.S. federal regulations. Chevron, decided in...
