Agence du revenu du Québec v. J.D. Irving Limited, 2022 QCCA 241

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Summaries

Summary Under

servicing fees paid by a property user to the owner for services that it performed on behalf of the owner were not leasing revenues

The taxpayer (“JDI”) and another pulp and paper company in the Irving group (“IPPL”) engaged in several transactions to effectively...

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Summary Under

agency relationship respected so as to permit owner to charge for services performed by user

A loss consolidation transaction involved a company (“IPPL”) in the Irving group of companies transferring, in December, its pollution control...

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