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Chriss – Federal Court of Appeal finds that a written resignation must be signed and delivered to the corporation to start the two-year s. 227.1(4) period running

29 September 2016- 9:25pm Chriss – Federal Court of Appeal finds that a written resignation must be signed and delivered to the corporation to start the two-year s. 227.1(4) period running Email this Content The husband of a director had instructed their law firm to prepare a written resignation for her, which they did, but the resignation form was never provided to her. In reversing a finding of Boyle J that this was sufficient to amount to a written resignation that started the two-year limitation period in s. 227.1(4) running, Rennie JA stated: …In the absence of the communication of a written resignation to the corporation, a resignation is not effective. … … Reliance on the subjective intention or say-so of a director alone would allow a director to plant the seeds of retroactive resignation, only to rely on it at some later date should a director-linked liability emerge. ...

21 January 2021 GST/HST Interpretation 202041 - […] Taxation of First Nation Trust […]

21 January 2021 GST/HST Interpretation 202041- […] Taxation of First Nation Trust […] Unedited CRA Tags ETA Part IX, 123(1), Indian Act: Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 10th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 202041 Dear [Client]: Subject: [GST/HST INTERPRETATION] […] Taxation of First Nation Trust […] Thank you for your letter of [mm/dd/yyyy], concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to professional services supplied to a trust established by […] [a First Nation] […]. ... You asked that the Canada Revenue Agency (CRA) include a trust in the definition of “band-empowered entity” found in GST/HST Technical Information Bulletin B-039, Administrative Policy – Application of the GST/HST to Indians (TIB B-039). ...

16 August 2022 GST/HST Ruling 225972 - & INTERPRETATION – […][Whether the Product is a zero-rated Basic Grocery item]

16 August 2022 GST/HST Ruling 225972- & INTERPRETATION – […][Whether the Product is a zero-rated Basic Grocery item] Unedited CRA Tags ETA Sch VI, Part III Sec. 1(m) Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... STATEMENT OF FACTS We understand the following: 1. […] (the Company) is a GST/HST registrant holding Business Number [...]. 2. ... Each individual […][item] weighs [#] grams. 4. The Product is sold and shipped to […][vendors] in cases of [#] […][items]. […], the Product is sold to consumers on an individual basis. 5. […], it is our understanding that the […][Product is] not individually packaged. […][The Product is shipped] in a frozen state […] thawed by the store [and kept refrigerated] for resale to customers. […]. ...

Canada (Attorney General) v. Fairmont Hotels Inc., 2016 SCC 56, [2016] 2 SCR 720 -- summary under Rectification & Rescission

., 2016 SCC 56, [2016] 2 S.C.R. 720-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification not available to correct planning errors With a goal of ensuring foreign exchange tax neutrality, Fairmont Hotels Inc. ... In finding that this rectification order should not have been given, Brown J stated (at paras 12, 19, 32 and 24): [R]ectification allows a court to achieve correspondence between the parties’ agreement and the substance of a legal instrument intended to record that agreement, when there is a discrepancy between the two. … The parties’ mistake in Juliar, however, was not in the recording of their intended agreement to transfer shares for a promissory note, but in selecting that mechanism instead of a shares-for-shares transfer. By granting the sought-after change of mechanism, the Court of Appeal in Juliar purported to “rectify” not merely the instrument recording the parties’ antecedent agreement, but that agreement itself where it failed to achieve the desired result or produced an unanticipated adverse consequence — that is, where it was the product of an error in judgment. … [T]he party seeking rectification must identify terms which were omitted or recorded incorrectly and which, correctly recorded, are sufficiently precise to constitute the terms of an enforceable agreement. ...

Black – Tax Court of Canada finds that an ancillary income-earning purpose for making a loan whose terms were never finalized was sufficient to satisfy s. 20(1)(c)(i)

24 June 2019- 12:57am Black – Tax Court of Canada finds that an ancillary income-earning purpose for making a loan whose terms were never finalized was sufficient to satisfy s. 20(1)(c)(i) Email this Content Conrad Black controlled both Hollinger Inc. ... Rossiter CJ accepted Black’s position that the borrowed money had been used by Black to make a loan to Inc., so that Black was entitled to an interest deduction on his borrowed funds, stating: … Black and Inc. reached an agreement on the essential terms of the loan and left the details to be worked out at a later date. The fact that a formal document outlining those essential terms was to be prepared later on and signed … does not alter the validity of the earlier contract. … Since Black had an obligation to pay interest expenses on the Quest Loan, Black had to earn interest income on the loan to Inc. in order for him to be made whole. … … While I find that this was an ancillary purpose compared to his primary purpose of helping Inc., that was a bona fide objective of his investment, which is capable of providing the requisite purpose for interest deductibility under paragraph 20(1)(c). ...

Adélard Soucy – Quebec Court of Appeal finds that a movable structure for warming a soldering operation was not Class 29 property

6 July 2021- 11:14pm Adélard Soucy – Quebec Court of Appeal finds that a movable structure for warming a soldering operation was not Class 29 property Email this Content The taxpayer custom-fabricated pieces of heavy specialized equipment at the northern mining site of one of its mining customers. ... …. The respondent's Econox serves primarily … to shelter the respondent's operations from the weather …. ... Adélard Soucy (1975) Inc., 2021 QCCA 1050 under Schedule II – Class 8. ...

T2 Corporation – Income Tax Guide – Chapter 3: Page 3 of the T2 return

T2 Corporation – Income Tax Guide – Chapter 3: Page 3 of the T2 return On this page... ... First year: 10% × $780,000 = $78,000 $78,000 ÷ 2 = $39,000 CCA (half-year rule) Second year: $780,000 − $39,000 = $741,000 (undepreciated capital cost) $741,000 × 10% = $74,100 CCA Third year: $741,000 − $74,100 = $666,900 (undepreciated capital cost) $666,900 × 10% = $66,690 CCA And so on for the following years. ... First year (2016): $9,000 ÷ 9= $1,000 $1,000 ÷ 2= $500 CCA (half-year rule) Second year and following (2017 to 2023): $1,000 CCA per year Last year of amortization period (2024): $1,000 × 1 1/2 = $1,500 CCA. ...

Church of Atheism of Central Canada – Federal Court of Appeal finds that refusal to register a Church of Atheism did not contravene the Charter

Rivoalen JA stated: [S]ection 2 of the Charter protects the rights of the appellant’s members to practise their beliefs in Atheism and the Minister cannot interfere with the practice of these beliefs …. ... The appellant can continue to carry out its purpose and its activities without charitable registration …. ... Canada (National Revenue), 2019 FCA 296 under Charter. s. 2 and ITA s. 149.1(1) – charitable organization – (a). ...

18 June 2015 STEP Roundtable Q. 15, 2015-0572151C6 - 2015 STEP Q15 - Tax Audit & Net Worth Statements

18 June 2015 STEP Roundtable Q. 15, 2015-0572151C6- 2015 STEP Q15- Tax Audit & Net Worth Statements CRA Tags 241 231.1(1) Principal Issues: Can CRA comment on auditors requesting personal financial information and/or furnishing statements of net worth of the shareholders of Canadian corporations? ... STEP CRA Roundtable June 18 2015 Question 15. Tax Audit and Net Worth Statements Can CRA comment on the following: a) It has come to our attention that CRA is increasingly requesting personal financial information of the shareholders of Canadian corporations which are selected for audit. ...

Sheila Holmes Spousal Trust v. Canada (Attorney General), 2013 ABQB 489 -- summary under Rectification & Rescission

Canada (Attorney General), 2013 ABQB 489-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission superior court declines jurisdiction in tax dispute The federal Minister assessed the settlor of the appellant trust on the basis that the trust's taxable capital gain and investment income were taxable in his hands because the trust was a sham or invalidly settled, or because s. 75(2) applied. ... In dismissing an application to the Court to declare that the trust was valid, Nixon J adverted to the principle in Addison & Leyen Ltd v Canada, 2007 SCC 33 (CanLII), [2007] 2 S.C.R. 793, at para. 11 that "Judicial review should not be used to develop a new form of incidental litigation designed to circumvent the system of tax appeals established by Parliament and the jurisdiction of the Tax Court," and stated (at para. 66): The only dispute with respect to the validity of the Trust is with the CRA in relation to the payment of tax. ...

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