Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375

In order to avoid B.C. provincial income tax on a capital gain of $336.2 million which was realized on a sale in 2002 of a control block of a...

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Fitzpatrick J. found that CRA had failed to establish neglect or carelessness in the filing position of the taxpayer ("Wesbild") given that such...

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The high rate of B.C. corporate income tax was avoided through rolling shares into a Yukon corporation (“Wesbild”), which purported not to...

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The filing position of the taxpayer (Wesbild), that it did not have a permanent establishment in B.C., was based on an application of the Marconi...

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Fitzpatrick J., after noting (at para. 101) that the French version of s. 152(4)(a)(i) rendered “misrepresentation” as “misrepresentation of...

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