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BlackRock HoldCo 5, LLC v Commissioners for His Majesty's Revenue and Customs, [2024] EWCA Civ 330-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 to make a cross-border inter-affiliate loan comparable in risk to the hypothetical independent enterprises’ loan, risk-protection covenants were to be imputed to the latter The structure for the acquisition by the BlackRock group of the U.S. target (“BGI”) entailed a BlackRock LLC (“LLC4”) lending US$4 billion to a wholly-owned LLC (“LLC5”) as well as injecting substantial equity into LLC5, with LLC5 using most of those proceeds to subscribe for preferred shares of the transaction Buyco (“LLC6” – which acquired all the shares of BGI). ...

(para. 48) “[T]he transactions were structured in the way they were to benefit Corco … [which] needed a way to finance the purchase.” ...

The only response was a call from a CRA complaints officer on January 18, 2024 advising that the Minister’s office would be responding to the two letters – which did not occur. ...

. … I can see no reason why that which is legitimate and proper outside the insolvency context should be viewed differently within it. ...

. … The US connections required by s.269B are limited to a) stapling of more than 50% by value of the foreign corporation's shares to those of a domestic corporation, and b) direct or indirect ownership as to 50% or more by US persons. ...

They accomplished what section 160 sought to prevent – its application, they defeated its underlying rationale, and they circumvented its application. ...

Furthermore, since in light of s. 251(6)(b) “a marriage ends on the death of one of the individuals … [t]o have the same rules apply to individuals in a common-law partnership, that relationship would also have to cease upon the death of one of the partners” (para. 44). ...

Before allowing the taxpayers appeal, Yuan J, stated (at para. 41): I have difficulty imagining what better evidence the CRA could reasonably expect an applicant to produce as proof of filing where the application was submitted by regular mail …. ...

The test is whether … may one say that the building was renovated sufficiently enough that all or substantially all of the building has been removed or replaced: Camiré v. ...

Agence du revenu du Québec, 2025 QCCQ 1127-- summary under Subsection 45(1) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1) the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use In 1981, the taxpayers (10 individuals), acquired as co-owners two adjoining rental buildings containing a total of 82 apartments, with their respective undivided interests in such properties ranging from 2.27% to 29.2%. ...