Royal Credit Services Inc. v. Ontario (Minister of Finance), 2026 ONSC 115

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Summaries

Summary Under

the Ontario-Quebec MOU does not apply to inconsistent methods for interprovincially allocating income as filed by the taxpayer

From 1994 to 2011, the applicant treated itself as a loan corporation (as described in Reg. 405 of the federal ITA Regulations) in its Quebec...

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Summary Under

inconsistency between Quebec treatment as loan corp. and Ont. treatment as general corp was by the taxpayer and out of MOU scope

In its 2011 returns, Royal Credit treated itself as a loan corporation (as described in Reg. 405 of the federal ITA Regulations) in its Quebec...

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