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Article 135(1)(d) of the Principal VAT Directive exempted “transactions, … concerning … payments, transfers, debts, … but excluding debt collection”. ... (a) of the financial service definition, which exempts the “payment … or transfer of money …”.) ... Summary of Target Group Ltd v Revenue and Customs [2023] UKSC 35 under ETA s. 123(1) – financial service – (a). ...

6 December 2018- 12:29am Burton – Federal Court of Australia finds that a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into income Email this Content An Australian-resident individual was taxed at the 15% long-term U.S. capital gains rate on his gains on the disposal of U.S. oil and gas drilling rights. ... The Article does not suggest that a credit is allowed against Australian tax payable for the whole amount of the US tax paid. … It does not prescribe how much is to be allowed as a credit. ... Summaries of Burton v Commissioner of Taxation [2018] FCA 1857 under s. 126(1) and Treaties – Income Tax Conventions – Art. 24. ...

25 August 2019- 11:54pm Burton – Full Federal Court of Australia confirms that a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into taxable income Email this Content An Australian-resident individual was taxed at the 15% long-term U.S. capital gains rate on his gains on the disposal of U.S. oil and gas drilling rights. ... Summaries of Burton v Commissioner of Taxation, [2019] FCAFC 141 under s. 126(1) and Treaties – Income Tax Conventions – Art. 24. ...

7 January 2018- 5:57pm Mac & Mac – Tax Court of Canada denies SR&ED claims because of inadequate notes of the work done Email this Content Mac & Mac was approached by a potential client to use its expertise in hydrodemolition to develop a technique to remove the worn inner linings from pipelines, so that the necessity of replacing them would be eliminated. Mac & Mac used numerous different approaches to applying high-pressure water to this end. In denying Mac & Mac’s SR&ED claims, Graham J stated: Mac & Mac’s claims … do not meet the last test [in Northwest Hydraulic which] … requires Mac & Mac to have kept detailed records of hypotheses, tests and results as the work progressed. … There is simply no way that someone, even someone very experienced in the industry, could hope to replicate or confirm Mac & Mac’s results from [its] notes. ...

10 April 2021- 11:41pm CRA is now applying a “proportionate attribution approach” in applying the EIA s. 5(2)(b) test of “control … of … voting shares” Email this Content S. 5(2)(b) of the Employment Insurance Act provides that “Insurable employment does not include … the employment of a person by a corporation if the person controls more than 40% of the voting shares of the corporation.” ... In stating that it accepted Boifor, so that its previous position was reversed, CRA addressed the example of two 50-50 (or 51-49) shareholders of a Holdco wholly owning their employer (Opco), and stated: In light of the FCA's decision, the CRA must now consider the proportionate attribution approach in similar situations to determine whether the employment of a person who controls more than 40% of the voting shares of the employing corporation is insurable. … … The proportionate attribution approach leads to the conclusion that the two shareholders each control more than 40% of Opco's voting shares (50% of 100%) for the purposes of EIA paragraph 5(2)(b). … … [W]here the shareholders held 51% and 49% of the voting shares of Holdco … their employment [also] would not be insurable because they had effective control of 51% and 49% of the voting shares of Opco …. ...

7 August 2017- 12:52am Halsall v Champion Consulting – High Court of England and Wales finds that knowledge that advice – that investing in a tax shelter was a “no brainer”- was negligent, commenced when HMRC started investigating Email this Content Investors in a UK charitable gift tax shelter subscribed for shares of a shell company and then, a short number of days later after the shell company had been listed on the AIM, donated their shares to a charity and claimed tax reductions on the basis that the shares had appreciated in value by four times. ... Summary of Halsall & Ors v Champion Consulting Ltd & Ors [2017] EWHC 1079 (QBD) under General Concepts – Negligence. ...

16 May 2017- 12:37am R & S Industries – Tax Court of Canada finds that a taxpayer is not bound by the statement of boot set out in its s. 97(2) election form Email this Content R & S Industries was unsuccessful in a motion to have the Federal Court direct CRA to reconsider its decision to not permit R & S Industries to file an amended s. 97(2) election form so as to change the agreed amounts. ... CRA viewed this as an attempted end-run around R & S’s inability to amend its election, and sought to have the appeal dismissed on jurisdictional grounds. ... Summary of R & S Industries Inc. v. The Queen, 2017 TCC 75 under s. 97(2). ...

As well … procedural gaffes are not so egregious as to require or demand denial of this application. ... Russell J stated in this regard that “there is a semblance of logic to … [the corporation’s] position, sufficient to constitute reasonable grounds.” ... Bureau Barrister & Solicitor Incorporated v. The Queen, 2020 TCC 119 under ETA s. 305(5)(b). ...

28 February 2023- 12:08am K & D Logging – Tax Court of Canada finds that a s. 20(21) deduction cannot offset previously-recognized s. 17 income Email this Content The taxpayer (K & D) initially recognized interest from year to year at the prescribed rate under s. 17 on a loan to a Uruguay farming corporation (Interan) of which it was a 44% shareholder. ... K & D argued that it could obtain a deduction under s. 20(21), for the amount of the interest previously recognized by it, on the loan’s disposition (its partial repayment). ... Summary of K & D Logging Ltd. v. The King, 2023 TCC 23 under s. 20(21). ...

17 December 2019- 12:03am Dow & Duggan – Tax Court of Canada finds that CRA does not have the discretion to stipulate the documentary requirements for direct-shipment export zero-rating Email this Content Sched. ... Summaries of Dow & Duggan Log Homes International (1993) Limited v. ...