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. … [I]n tax matters, where the federal and provincial provisions are appreciably in the same form, a presumption of coherence between the two provisions should prevail. ...

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). ...

. … 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. ...

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%. ...

Indeed … Gilbert v. Agence du revenu du Québec, 2018 QCCA 1792 para. 23 …recognized that through the adoption of this provision, the legislator's intention to prevent the misappropriation of taxes and source deductions by corporate directors is evident. ...

. … [T]he fact that Chapter 2 was introduced partly for the purpose of forestalling tax avoidance schemes self-evidently makes it difficult to attribute to Parliament an intention that it should apply to schemes which were carefully crafted to fall within its scope, purely for the purpose of tax avoidance. ...

Ss. 26(1) and (2) provided that the amount of allowable input tax is that which is “attributable to” taxable “supplies … made or to be made by the taxable person in the course or furtherance of his business.” ...

It is the place that Courts of Appeals have called the corporation's 'nerve center' … and not simply an office where the corporation holds its board meetings….” ...

Lagotte Succession, 2017 QCCS 330 (Quebec Superior Court)-- summary under Subsection 70(6.2) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6.2) executor was authorized under will to choose not to elect Under the will of his deceased wife, the plaintiff (Picard) was a legatee by particular title of her principal residence as well as of an apartment building on which there was a substantial accrued gain – but was not one of the residuary beneficiaries under her will. ...