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Dimane Enterprises Ltd. v. The Queen, 2015 DTC 1013 [at at 64], 2014 TCC 334 -- summary under Payment & Receipt

The Queen, 2015 DTC 1013 [at at 64], 2014 TCC 334-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payments not received where children "recipients" had no control over funds Purported distributions out of a purported EPSP to children employees of the taxpayer were to a bank account controlled by the father, so that the participants "never had control of these funds" (para. 40), and so that the "real transactions" were "the payment of amounts by the corporation to the father" (para. 42). ...

Flinn v. MNR, 3 DTC 1157, [1948] Ex. C.R. 272 (Ex Ct) -- summary under Payment & Receipt

C.R. 272 (Ex Ct)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt note issued evidencing payment obligation Dividends on preference shares of a corporation, including those held by the taxpayer, were substantially in arrears. ...

Pierre Elliott Trudeau Foundation v. Millenium Golden Eagle International (Canada) Inc., File No. 500-17-125795-230 (Quebec Superior Court) -- summary under Rectification & Rescission

., File No. 500-17-125795-230 (Quebec Superior Court)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission annulment ordered of two donations The plaintiff (the Foundation) received two donations, each of $70,000, from the defendant (Millenium) in July 2016 and July 2017. ...

Imperial Oil Resources Limited v. Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037 -- summary under Payment & Receipt

Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt embedded royalty reduction was not an amount received The Alberta government granted a reduction in the royalties the taxpayer otherwise would have been required to pay to Alberta on condition that the taxpayer invest in an expansion of the Syncrude project. ...

Rémillard – Federal Court of Appeal finds that the CRA records transmitted to the Federal Court Registry were open to the public absent a specific confidentiality order

After agreeing with Pamel J below that such documents were part of the court file and thus accessible to the public under Rule 26 unless a confidentiality order was obtained, Montigny JA went on to reject the taxpayer’s submission (in reliance on Gernhart) that making the certified record public as a matter of course violated section 8 of the Charter, stating: Anyone engaging the courts in an action … must expect that large parts of his or her private life will become publicly accessible. … Far from transmitting confidential information without his consent and without informing him, it was rather at Mr. Rémillard's own request that the Minister transmitted the relevant documents to the Court Registry. … … Mr. Rémillard could have … requested the Court to issue an order to protect the confidentiality of certain information contained in the documents transmitted. ...

Glencore – Tax Court of Canada finds that a break fee was income from a business

In fact, another public company (“Inco” – the 25% minority shareholder) made a subsequent offer that was accepted by DFR, thereby triggering the payment by it of the break fee. ... Falconbridge was carrying on its business when it negotiated the Merger … Agreement[s], … which provided for the fees in dispute. … The … Fees were ancillary business income received by Falconbridge in the course of earning income from business. ... The Queen, 2021 TCC 63 under s. 9 – compensation payments. ...

7 November 1994 External T.I. 9400965 - U.S. REAL PROPERTY INTEREST & FTC (5638-2) -- summary under Article 24

REAL PROPERTY INTEREST & FTC (5638-2)-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 FTC for U.S. ... Income Tax Convention …, the U.S. has the right to tax Mr. A's gains on the disposition of his Canco's shares, as described … above. ... As a result … Mr. A would qualify to claim a foreign tax credit under subsection 126(1) … in respect of [such] U.S. tax liability…. ...

Caisse Desjardins de Limoilou – Quebec Court of Appeal finds that a mortgagee’s prescribed security interest was reduced under Reg. 2201(2)(a) by the shareholders’ guarantee

Gagné JCA stated: First, the ordinary meaning of the words "rights of the secured creditor …" refers to all the economic rights of the secured creditor securing the obligation. There is nothing in the text of [Reg.] 2201(2)(a) … to limit these rights to the real property rights of the secured creditor [as argued by the Caissse]. … Second, the legislator was careful to add "including guarantees …” … The word "guarantees" must be taken in its broad sense, which includes suretyship. … Third, the [Finance] Explanatory Notes to the Regulations support this interpretation. … In rejecting a further argument of the Caisse that the Reg. was contrary to “the rule prohibiting the granting of pure discretion by Regulation,” she stated that the Reg. was not purely discretionary and, in fact, its meaning “can easily be determined by applying the modern method of interpretation.” ... Caisse Desjardins de Limoilou, 2020 QCCA 1612 under Reg. 2201(2)(a) and Statutory Interpretation – Regulations/Statutory Delegation. ...

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. ...

Greither Estate v. Canada (Attorney General), 2017 BCSC 994 -- summary under Rectification & Rescission

Canada (Attorney General), 2017 BCSC 994-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission taking back excess boot could not be rectified under the BCA provision for correcting “corporate” mistakes 627291 B.C. ... There has not been: (a) a breach of a provision of the BCA, a former Company Act or the regulations under any of them; (b) a default in compliance with the memorandum, notice of articles or articles of the company; and … (c) none of the following proceedings at or in connection with any of the following have been rendered ineffective: (i) a meeting of shareholders; (ii) a meeting of the directors or of a committee of directors; (iii) any assembly purporting to be a meeting referred to in subparagraph (i) or (ii); and (d) a consent resolution or records purporting to be a consent resolution has not been rendered ineffective. … [T]he mistake of not completing the Transaction in the most tax effective manner does not … fall within these subsections. ... Mayer J further found (at para 40 and 41): Even if the Greither Estate was seeking the remedy of equitable rectification, … I am not satisfied that the facts of this case would justify such relief…. ...

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