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3308367 Canada – Court of Quebec confirms that a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA

27 March 2025- 10:03am 3308367 Canada – Court of Quebec confirms that a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA Email this Content The ARQ assessed the taxpayer within two years of the taxpayer’s dissolution pursuant to s. 210(3) of the CBCA. ... ARQ, No. 500-80-043022-228 (17 March 2025) under CBCA s. 226(2)(b). ...

Galea – Privy Council finds that whether an activity qualifies as “carried on with a view to profit" turns on the taxpayer’s subjective intention

9 April 2025- 11:35pm Galea – Privy Council finds that whether an activity qualifies as “carried on with a view to profit" turns on the taxpayer’s subjective intention Email this Content Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade … or undertaking, or any other income earning activity, carried on with a view to profit. ... Summary of Galea v The Assessment Review Committee & Anor (Mauritius) [2025] UKPC 17 under s. 3(a) – business. ...

Sura – Court of Quebec finds that 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

14 April 2025- 11:35pm Sura – Court of Quebec finds that 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 Email this Content In 1981, 10 individuals acquired as co-owners two adjoining rental buildings containing a total of 82 apartments. ... Agence du revenu du Québec, 2025 QCCQ 1127 under s. 45(1). ...

Vortex – Tax Court of Canada characterizes purported SR&ED as routine engineering conducted by trial and error

22 May 2025- 11:52pm Vortex – Tax Court of Canada characterizes purported SR&ED as routine engineering conducted by trial and error Email this Content In confirming the denial of the claim of the taxpayer that it had engaged in experimental development in building mobile direct-contact water heaters for use in fracking, Spiro, J. found inter alia that there was an absence of any expert evidence demonstrating technological risks or uncertainties which could not have been removed by routine engineering or standard procedures, and that the work could instead be characterized as routine engineering that was conducted by trial and error. ... The King, 2025 TCC 63 under s. 248(1) – SR&ED. ...

Bell Canada – Federal Court of Appeal finds that Ontario electricity suppliers made single supplies of electricity notwithstanding separate regulatory and delivery charges

5 February 2025- 8:02am Bell Canada – Federal Court of Appeal finds that Ontario electricity suppliers made single supplies of electricity notwithstanding separate regulatory and delivery charges Email this Content Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ... In affirming this finding, Boivin JA distinguished Kevin Davis Dentistry, which gave effect to the expressed Parliamentary intent to “provide for different tax treatment of supplies of orthodontic appliances and orthodontic service” whereas, here, the Ontario regulations did “not amount to as clear an indicator of Parliament’s intent as the GST Act did in Kevin Davis Dentistry ”. ... Canada, 2025 FCA 27 under ETA s. 123(1) – supply. ...

Grenon RRSP – FCA finds that significant distributions of fund units to minors meant that those units had not been lawfully distributed – so that they were not MFTs

7 July 2025- 12:23am Grenon RRSP – FCA finds that significant distributions of fund units to minors meant that those units had not been lawfully distributed – so that they were not MFTs Email this Content Mr. ... In rejecting this position, Monaghan JA noted 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. ... Canada, 2025 FCA 129 under Reg. 4801, s. 207.1(1)(a) and s. 152(3.1). ...

1351231 Ontario – Federal Court of Appeal confirms that conversion of the use of a condo from long-term rental to an Airbnb property caused its subsequent sale to be taxable

9 March 2025- 11:17pm 1351231 Ontario – Federal Court of Appeal confirms that conversion of the use of a condo from long-term rental to an Airbnb property caused its subsequent sale to be taxable Email this Content The Appellant used a condo unit for the first nine years after purchase for long-term residential rentals and then listed it on Airbnb and rented it out for succession of short-term rentals (under 60 days and sometimes for only one night) before its sale. ... Canada, 2025 FCA 53 under ETA s. 123(1) – residential complex. ...

Seabridge – BC Supreme Court finds that pre-feasibility expenses to assess whether a deposit could potentially support a mine qualified as exploration expenses

28 March 2025- 12:33am Seabridge – BC Supreme Court finds that pre-feasibility expenses to assess whether a deposit could potentially support a mine qualified as exploration expenses Email this Content Seabridge incurred various pre-feasibility expenses in relation to a large and complex gold-bearing deposit in BC. ... Summary of Seabridge Gold Inc. v British Columbia, 2025 BCSC 558 under s. 66.1(6) – CEE – (f). ...

Wong – Tax Court of Canada engages in a detailed weighing exercise to determine that two ex-spouses were shared custody parents

24 February 2025- 11:59pm Wong – Tax Court of Canada finds engages in a detailed weighing exercise to determine that two ex-spouses were shared custody parents Email this Content After initially denying the Canada child benefit (CCB) claims of the taxpayer in full (on the basis that it was her ex-husband who primarily fulfilled the care responsibilities for their son), CRA assessed her on the basis that they were “shared custody parents,” so that she was entitled to 50% of the CCB amounts. ... The King, 2025 TCC 24 under s. 122.6 – shared-custody parent. ...

Ehresman – Tax Court of Canada finds that cash reserves were not active business assets because they were excessive in relation to reasonably-determined risks

5 June 2025- 11:14pm Ehresman – Tax Court of Canada finds that cash reserves were not active business assets because they were excessive in relation to reasonably-determined risks Email this Content Whether the sale by a couple of their shares of a private corporation (CCM) with producing Canadian oil wells and a Canadian financial services business constituted a sale of qualified small business corporation shares (QSBCS) turned on whether their CCM shares satisfied the test in the QSBCS definition of more than 50% of the fair market value (FMV), over the 24 months preceding the disposition, of their shares being attributable to assets used principally in CCM’s active business. ... The King, 2025 TCC 78 under s. 110.6(1) – QSBCS. ...

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