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BCM Cayman LP & Anor v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 1179 -- summary under Subsection 102(2)

BCM Cayman LP & Anor v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 1179-- summary under Subsection 102(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 102- Subsection 102(2) a two-tier partnership structure can be legally respected as such if the upper-tier partnership is a limited partnership The taxpayer (“Cayman Ltd.”) was a Cayman company which was the general partner of a Cayman LP (“Cayman LP”). ... He was not considering the position of limited partners in a limited partnership, whose role is limited and circumscribed by statute. … Cayman LP's business was carried on by its general partner (Cayman Ltd) and … the limited partners (including Fyled) were prohibited by Cayman law from taking part in Cayman LP's business …. ... A further basis for finding that Fyled was not a member of the UK LLP was that Cayman LP could not (and was not) recorded as a member of the UK LLP, nor was Fyled (para. 47): In any event, UK LLP is a UK corporate body governed by the Limited Liability Partnership Act 2000 which imposes a number of requirements, including … the requirement that members must subscribe their name to the incorporation document …. ...

6 September 2018 GST/HST Ruling 185555 - – […][The Product] – […][Flavour 1] and […][Flavour 2] [Basic Groceries]

The back of the bag notes the ingredients of the Product and describes the Product as being “[…]”. 8. [Flavour 1] of the Product has the following ingredients: […]. 9. [Flavour 2] has the following ingredients: […]. 10. The manufacturer’s Web site, […], states that the Product is […][Product details]. 11. ...

7 August 1990 Income Tax Severed Letter - Cape Breton Investment Tax Credit Program — date of acquisition of property — foreign exchange rate

7 August 1990 Income Tax Severed Letter- Cape Breton Investment Tax Credit Program — date of acquisition of property — foreign exchange rate Unedited CRA Tags none Subject: Cape Breton Investment Tax Credit (CBITC) Program_ Date of Acquisition of Property-Foreign Exchange Rate This is in reply to your Memorandum dated March 13, 1990 whereby you requested our opinion concerning the determination of the date of acquisition of certain equipment and the treatment of variations in exchange rates in respect of part of the purchase price paid before the date of acquisitions of the equipment. ... As stated in paragraph 6 of IT-50R: “... property can pass and acquisition take place only if the asset is in existence and, even then, only if it is a `specific asset', i.e. one that is capable of being identified as the object of the contract.” ...

7 August 1991 Income Tax Severed Letter - Nova Scotia R & D Tax Credit - Ontario R & D Super Allowance

7 August 1991 Income Tax Severed Letter- Nova Scotia R & D Tax Credit- Ontario R & D Super Allowance Unedited CRA Tags 12(1)(x), 37(1)(d), 127(9), 127(11.1) Dear Sirs: Re: Nova Scotia Research and Development (`R&D') Tax Credit Ontario R&D Super Allowance We are writing in reply to your letter of June 3, 1991 in which you requested a technical interpretation as to why the Nova Scotia R&D Tax Credit is considered to be government assistance for the purpose of paragraph 12(1)(x) of the Income Tax Act (the "Act") while the Ontario R&D Super Allowance is not. ...

R I S - Christie Ltd. v. Canada, 99 DTC 5087, [1999] 1 CTC 132 (FCA) -- summary under Scientific Research & Experimental Development

Canada, 99 DTC 5087, [1999] 1 CTC 132 (FCA)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer was entitled to have its expenditures treated as SR&ED notwithstanding the absence of documentary evidence relating to the repeatability of the testing data. ...

Fairmont Hotels Inc. v. A.G. Canada, 2014 ONSC 7302, aff'd supra, rev'd 2016 SCC 56 -- summary under Rectification & Rescission

Canada, 2014 ONSC 7302, aff'd supra, rev'd 2016 SCC 56-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission continuing non-specific intention to maintain a tax neutral structure In order to facilitate the acquisition in 2002 of a hotel in Washington by a REIT ("Legacy") of which it was the manager, Fairmont Hotels Inc. ... As he was bound by Juliar, he did not have the "luxury" of following Graymar and, in any event, he did not think that Brown J in that case "has accurately described what happened in Juliar " (para. 41). ...

Line 25500 – Prescribed Zones – Alberta

Line 25500 – Prescribed Zones – Alberta Place names followed by numbers are Indian reserves. ... Alberta Table of the prescribed northern or intermediate zones for Alberta Zone A – Prescribed Northern Zones Zone B – Prescribed Intermediate Zones Place names followed by an asterisk "*" indicates that the location is in Wood Buffalo National Park. Adams Landing Amber River 211 Angus Tower * Assumption Beaver Ranch 163 Berdinskies Big Slough Bistcho Lake 213 Boyer Boyer 164 Boyer Settlement Buffalo Head Prairie Bushe River 207 Carcajou Carlson Landing Chateh Cherry Mountain * Child Lake 164A Chipewyan 201 Chipewyan 201A Chipewyan 201B Chipewyan 201C Chipewyan 201D Chipewyan 201E Chipewyan 201F Chipewyan 201G Davidson Lake * Embarras (Athabasca River) Embarras Portage Fifth Meridian Fitzgerald (Slave River) Footner Lake Forestry West Zama (airfield) Fort Chipewyan Fort Smith Settlement Fort Vermilion Fox Lake Fox Lake 162 Garden Creek Garden River (Pakwanutik River) Habay Hay Camp Hay Lake 209 High Level High Rock * Hutch Lake Indian Cabins Jackfish Jackfish Point 214 Jackfish River John D'Or Prairie John D'Or Prairie 215 Keg River Kemp River Kenny Woods La Crête Lambert Creek Tower Little Fishery Little Red River Lutose Margaret Lake Meander River Meander River Station Metis North Vermilion Settlement Old Fort Paddle Prairie Paddle Prairie Metis Settlement Parsons Lake * Peace Point Pine Lake * Point Brule Quatre Fourches Rainbow Imperial (airfield) Rainbow Lake Rocky Lane Slavey Creek Steen River Sweetgrass Landing Tall Cree 173 Tall Cree 173A Upper Hay River 212 Vermilion Chutes Wadlin Tower Warden Station * Wentzel Lake Zama Lake Zama Lake 210 Aggie Agnes Lake Albright Algar Amesbury Anzac Arcadia Assineau Assineau River 150F Atikameg Avenir Bad Heart Ballater Bay Tree Bear Canyon Beaverlodge Behan Belloy Berwyn Bezanson Bison Lake Bitumount Blueberry Mountain Bluesky Bonanza Braeburn Brainard Breynat Bridgeview Brownvale Buffalo Lake Cadotte Lake Calais Calling Lake Calling River Canyon Creek Chard Cheecham Cherry Point Chinook Valley Chipewyan Lake Clairmont Clarkson Valley Clear Hills Clear Hills 152C Clear Prairie Cleardale Clearwater 175 Codesa Conklin Cowper (airfield) Crooked Creek Culp Culp Station Deadwood Debolt Decrene Deer Hill Demmitt Devenish Dimsdale Dixonville Donnelly Draper Dreau Drift Pile River 150 Driftpile Duncan's 151A Dunvegan Eaglesham Early Gardens Elmworth Enilda Erin Lodge Eureka River Fairview Falher Faust Fawcett Lake Fitzsimmons Forest View Fort MacKay Fort McKay 174 Fort McMurray Freeman 150B Friedenstal Gage Gift Lake Gift Lake Metis Settlement Gilwood Girouxville Glen Leslie Goodfare Goodwin Gordondale Grande Prairie Gregoire Lake 176 Gregoire Lake 176A Gregoire Lake 176B Griffin Creek Grimshaw Grist Lake (airfield) Grouard Grouard Mission Grovedale Guy Halcourt Halcro 150C Harmon Valley Hawk Hills Hayfield Hazelmere Heart River Heart Valley Hermit Lake High Prairie Highland Park Hines Creek Hinton Trail Homestead Hondo Horse Lakes 152B Hotchkiss House River Indian Cemetery 178 Huallen Hythe Imperial Mills Janvier 194 Jean Baptiste Gambler 183 Jean Côté Joussard Judah Kathleen Kenzie Kinosis Kinuso Kleskun Hill Ksituan La Glace Lac Magloire Lake Saskatoon Last Lake Leddy Leicester Leighmore Leismer Lenarthur Lesser Slave Lake Settlement Little Buffalo Loon Lake Loon River Lothrop Lubicon Lake Lymburn Lynton Manir Manning Manning Station Margie Mariana Lake Marie-Reine Marie-Reine Station Marina Marten River McLennan Mildred Lake Mitsue Moose Portage Mount Valley Nampa Namur Lake 174B Namur River 174A New Fish Creek Niobe Normandville North Star Northmark Notikewin Overlea Pakashan 150D Peace Grove Peace River Peerless Lake Pelican Portage Peoria Philomena Pingle Pipestone Creek Pitlochrie Poplar Hill Poplar Ridge Prairie Echo Prestville Quigley Ranch Red Earth Creek Red Star Reno Rio Grande Roma Roma Junction Roxana Royce Rycroft St. ...

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. ...

Bourgault v. The Queen, 2019 TCC 6 -- summary under Rectification & Rescission

The Queen, 2019 TCC 6-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission a rectification judgment was “justifiably obtained” and, therefore, followed for tax purposes On April 15, 2002, the taxpayer signed an agreement for the purchase of shares of a real estate corporation (“Quatre Saisons”) that stated that the purchase price was to be satisfied by the payment to the vendor (“Placeval,” a corporation owned by a Mr. ... Before granting the taxpayer’s appeal from the assessment, Favreau J stated (at paras. 55, 59-60, 62): [T]he judgment of the Superior Court is not binding on the respondent as neither the Attorney General of Canada nor the Minister was involved in the application. … Although the judgment of the Superior Court is not binding on the respondent and is not res judicata, the conduct of the parties, both before and after the concluding of the transaction, clearly demonstrates their true intention to purchase and sell the shares of Quatre Saisons for nominal consideration and not for consideration based on the future sales of lots. ... The financial statements of Quatre Saisons for its fiscal years ending on March 31 of 2003, 2004 and 2005, also reflected the commissions paid in the cost of the sales of the lots. … [I]t is evident that the agreement, as reduced to writing, contained drafting errors of material importance …. ...

Clark v HM Revenue and Customs, [2020] EWCA Civ 204 -- summary under Payment & Receipt

Clark v HM Revenue and Customs, [2020] EWCA Civ 204-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt there can be a payment even where there is a resulting trust in favour of the payor The taxpayer, a retired UK businessman, implemented a scheme to transfer funds (the “Suffolk Life Transfer") from his self-invested personal pension plan ("SIPP") to a second pension scheme (the “LML Pension,” of which the taxpayer was the sole member and whose named employer was a Cyprus company that entered into an employment contract with the taxpayer) in order to free up those funds for investment by him in the London residential property market. ... Unbeknownst to the participants, the LML Pension was void for uncertainty, as to which Henderson LJ stated (at para. 37): It is agreed … that the effect of the failure of the trusts of the LML Pension is that the transfer conveyed only bare legal title to the money, because an immediate resulting trust arose by operation of law. ... The money was intended to pass from the control and supervision of one registered pension scheme to another …. ...

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