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Lussier – Court of Quebec finds no taxable benefit in an insurance company employee attending a conference for insurance brokers in Cancun

14 February 2022- 11:01pm Lussier – Court of Quebec finds no taxable benefit in an insurance company employee attending a conference for insurance brokers in Cancun Email this Content The taxpayer, was designated by his employer (“BMO,” an insurance company) to attend a one-week conference for insurance brokers and financial advisors whom one of BMO’s managing general agents had identified as top “performers.” ... In reversing the ARQ assessment to include 62.5% of the cost of the trip in the taxpayer’s income as a taxable benefit, Pilon JCQ stated: The recreational activities were an opportunity to create or maintain relationships with advisors and brokers. … … [T]he ARQ's … approach is somewhat penalizing and unfair to Mr. ... His employer did not give him the choice to participate in a trip, on which he went alone, and where he was expected to work and develop business, which he did, both during business hours and beyond. … [T]he ARQ's position stems either from a misunderstanding of what constitutes the steps required for business development where there is a legitimate growth objective, or from a desire to dictate to a business what its business model should be and how to achieve it. ...

Chad – Tax Court of Canada finds that the presumption that commercial activity is in pursuit of profit and, thus, a source, was rebutted where there was no real interest in generating profit

The documentary evidence … does not give any indication that Mr. Chad … intended, in conducting the FX Activities, to achieve a profit/loss amount great enough to offset the $240,000 fee, which was a significant expense …. Thus … the intention of Mr. Chad … in implementing the Trades, was not to earn a profit …. ... The King, 2024 TCC 142 under s. 3(1) – business, and General Concepts- Sham. ...

Jimenez – Court of Appeal of England and Wale finds that a demand for information issued to a former UK resident was valid

Leggatt LJ stated: Counsel for Mr Jimenez … relied on a distinction … adopted … [by Rossiter CJ] in Oroville Reman & Reload … between documents of notice that merely involve the supply of information with no threat of penalties in the event of non-compliance and documents involving a compulsory process or containing a command. ... Such a measure does not involve the performance of any official act within the territory of another state – as would, for example, sending an officer of Revenue and Customs to enter the person's business premises in a foreign state and inspect business documents that are on the premises …. [T]he imposition of a civil penalty … for failure to comply with such a taxpayer notice would [not] involve an exercise of enforcement jurisdiction … provided that no steps are taken to seek to enforce the penalty in a foreign state. ...

National Exhibition Centre – European Court of Justice finds that a fee for arranging for credit card payments for tickets was not exempt from VAT

21 June 2016- 11:22pm National Exhibition Centre – European Court of Justice finds that a fee for arranging for credit card payments for tickets was not exempt from VAT Email this Content The owner of a British exhibition centre (“NEC”) sold tickets on behalf of third parties holding events at the centre. ... Summaries of HMRC v National Exhibition Centre Ltd., [2016] BVC 19 under ETA – s. 123(1) – supply, s. 123(1) – financial service – para. ...

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27 -- summary under Subsection 18(9.1)

[Footnote 65 See, for example, paragraphs 1.22 and 1.38 of … S4-F2-C1 … 2012-0436771E5 … and … 9325325 ….] ... Alternatively, if the intermediary is considered to be in the business of lending money, consideration could be given to whether the penalty paid might be deductible, under section 9 …. [I]t might be possible for the intermediary to avoid the payment and receipt of the prepayment penalty by assigning its debt receivable to the ultimate lender in satisfaction of the intermediary’s debt to the ultimate lender …. ...

Henco – Tax Court of Canada finds that compensation received for a destroyed business was completely tax-free

24 June 2014- 11:13am Henco – Tax Court of Canada finds that compensation received for a destroyed business was completely tax-free Email this Content The Ontario government capitulated to Six Nations protesters, who occupied the subdivision property of the taxpayer (Henco), by passing a by-law prohibiting any use of the property (thereby rendering it valueless and (per C. ... The Queen, 2014 DTC 1161 [at 3528], 2014 TCC 192 under s. 9 – compensation payments, s. 12(1)(x), s. 14(5) – cumulative eligible capital, s. 23, General Concepts – fair market value – land, and General Concepts – evidence. ...

Canada (Attorney-General) v. Brogan Family Trust, 2014 ONSC 6354 -- summary under Rectification & Rescission

Brogan Family Trust, 2014 ONSC 6354-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission no obligation to notify Crown if tax liability which was relieved has not been assessed The respondent family trust obtained a rectification order, to permit trust distributions to minor grandchildren beneficiaries, on 26 November 2010, which was shortly after a sale of a business by the trust. ... In dismissing this motion, Ray J stated (at para. 13): I am not persuaded that… CCRA [sic] was affected by the order of McLean, J. … [After citing Canada v. ... Richter & Associates, [2000] OJ No. 2073 (Ont SC) aff'd [2001] OJ No. 1087 (Ont CA)]. ...

Felty v. Ernst & Young LLP, 2015 BCCA 445 -- summary under Agency

Ernst & Young LLP, 2015 BCCA 445-- summary under Agency Summary Under Tax Topics- General Concepts- Agency presumption that law firm agreement binds client The appellant’s B.C. law firm retained Ernst & Young to provide her with U.S. tax advice in connection with negotiating a separation agreement with her husband. ... In finding that the appellant was bound by the engagement agreement, Newbury JA applied (at para. 38) the principle in Shaw, Salter & Plommer v. Phipps & Cosgrove (1926) 37 B.C.R. 184 “that as a general rule, solicitors will be taken to be contracting on behalf of their clients in the course of their practice.” ...

Robotx Solutions Inc. v. The Queen, 2017 TCC 73 (Informal Procedure) -- summary under Scientific Research & Experimental Development

The Queen, 2017 TCC 73 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development solving narrowly-cast production engineering problems was not SR&ED The taxpayer was a corporation that improved customer’s equipment by increasing their lifespan, improving their security mechanisms or by standardizing them in order to produce economies of scale. In 2012, it entered into four separate contracts with four customers to provide them with specific solutions within the scope of this services business, and treated $182,483 of the expenditures which in incurred in the course of performing this customer-specific work as SR & ED expenditures. Respecting the first project undertaken for an alcohol products company, Jorré J stated (at paras 50, 58, and 62-63, TaxInterpretations translation): … [T]he purpose of the project was to make the palletizers and depalletizers [of beverage bottles] conform to current security standards and to eliminate the risk of the lifting platform falling when an operator or mechanic was underneath. … … [T]here is nothing in the evidence that suggests that palletizers and depalletizers meeting the required safety standards do not already exist or that there is an improvement over what already existed. … … Difficulties by themselves are not sufficient for their resolution to become experimental development. ...

Bosa v Canada, 2025 BCSC 1284 -- summary under Rectification & Rescission

Bosa v Canada, 2025 BCSC 1284-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission BCSC lacked the jurisdiction to consider a request to rectify a clause in a family trust indenture whose interpretation was at issue in an impending TCC appeal The petitioners were the beneficiaries of a family trust, who sought to rectify the terms of the Trust Indenture to clarify that the assets of the trust had vested indefeasibly in them on the date defined in the Trust Indenture as the "Distribution Date," which occurred approximately 10 months before the 21st anniversary of the formation of the trust. ... Canada … 2013 ABQB 489, at para. 61. … The interpretation of the Trust Indenture which they [the petitioners] urge me to adopt is based on the same arguments that the Reassessment officer considered and rejected. Those arguments are the subject of the appeal to the Tax Court …. In further finding that, even if she had jurisdiction, rectification would not be appropriately granted, she stated (at para. 58) that “[i]t is well established that equitable relief is not available to avoid unanticipated adverse tax consequences which arise from the ordinary operation of the Income Tax Act … Collins Family Trust ….. ...

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