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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%. ...

Canada, 2025 FCA 129-- summary under Subsection 207.1(1) Summary Under Tax Topics- Income Tax Act- Section 207.1- Subsection 207.1(1) since FMV of non-qualified investments was required to be included in the annuitant’s income (even though such inclusion was not reported or assessed) it was excluded from Pt. ... In rejecting this position, Monaghan JA noted (at para. 303) that s. 56(1) provides that "there shall be included in computing the income of a taxpayer for a taxation year" the amount described in that section, including "amounts required by section 146 in respect of a [RRSP] … to be included in computing the taxpayer's income for the year," and s. 146(10), in turn, stated that where an RRSP acquired a non-qualified investment, the acquisition date value "shall be included in computing the income for the year of the taxpayer who is the annuitant. ...

The Queen, 2021 TCC 30, aff'd in part 2025 FCA 129-- summary under Subsection 207.2(3) Summary Under Tax Topics- Income Tax Act- Section 207.2- Subsection 207.2(3) CRA’s assessment of Pt. ... Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...

Agence du revenu du Québec, 2025 QCCQ-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) s. 160 can apply to a s. 227.1 liability of a director who was not assessed therefor until well after the subject transfer An individual (Larocque) was a director and shareholder of a corporation (Construction LMA), engaged in the development of residential projects. ... 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. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 an oil and gas royalty is not income from immovable property under the Canada-U.K. ... In concluding on this issue, she stated (at para. 97): … RBC does not hold, and indeed has never held, an interest in the Buchan field. ...

Canada, 2025 FCA 129-- summary under Regulation 4801 Summary Under Tax Topics- Income Tax Regulations- Regulation 4801 distribution of units to minors so as to fail to achieve the targeted minimum of qualified investors purchasing under an offering memorandum was not a lawful distribution The appellant subscribed $310 million for units of various income funds, which were intended to qualify as mutual fund trusts on the basis that each had received subscription proceeds totaling $128,250 from 171 investors, with each such investor subscribing for 100 units at $7.50 per unit. ... She stated (at para. 133) that “the minimum beneficiary condition might also be satisfied through a unitholder transferring units to others” and (at para. 145) that she was satisfied that, in the context of the ITA, "’hold’ is intended to mean ‘own’, unless the context in which it is used indicates otherwise” – which was not the case regarding Regulation 4801. ...