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Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by direction A Canadian corporation ("C&A") paid two dividends to its Canadian-resident parent ("Holdings"), which distributed the same amounts to its U.S. ...

Ashmore & Ors., [1995] BTC 406 (CA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission intended terms not clear A deed for payment of £70,000 to charity, although it was intended to comply with an income tax requirement that the payment be for a period which might exceed three years, was executed in terms that ensured that the period would not exceed three years. ...

Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt presumed application to oldest debt The taxpayer's practice, in determining its allowance for doubtful accounts at the end of its taxation year on November 27, 1082, included having regard to payments made by trade debtors during the three months after that its year end, but treating receipts as going to the oldest receivables first. ...

David Richards LJ stated (at paras. 111-112): The clear conclusion to which the FTT came … was put by the FTT at [422], "the Jersey directors were acting under what they considered was an 'instruction' or 'order' from the parent". The inevitable conclusion from that finding was … that the decision to enter into the relevant transactions was taken by the parent in the UK, not by the directors in Jersey. They were, of course, concerned to ensure that what they were being instructed to do was lawful. … Likewise, the directors were concerned to ensure that there were no unexpected liabilities for the Jersey companies, such as stamp duty, and to ensure that the documents were in proper order. ...

Travel Document Service & Ladbroke Group International v Revenue & Customs (Rev 1), [2018] EWCA Civ 549-- summary under Interpretation/Definition Provisions Summary Under Tax Topics- Statutory Interpretation- Interpretation/Definition Provisions where an anti-avoidance provision’s application depended on the purpose of being a creditor, that purpose was the one for holding shares which were a deemed loan A British taxpayer (TDS) used a total return swap to cause its share investment in a subsidiary (LGI) to be deemed to be a loan. ... That being so, I agree with Mr Ghosh [for HMRC] that the inescapable inference was that securing the advantage had become a main purpose of holding the shares. … He also rejected HMRC’s submission that "’main’ … means ‘more than trivial’," stating (at para. 48): A purpose can be "more than trivial" without being a "main" purpose. ...

Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163, [1992] 1 CTC 2218 (TCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no payment by mere book entry Bowman J. stated: A mere bookkeeping entry in a loan account by itself does not constitute a taxable event unless there is something more, such as receipt. ...

Travel Document Service & Ladbroke Group International v Revenue & Customs (Rev 1), [2018] EWCA Civ 549-- summary under Subsection 83(2.1) Summary Under Tax Topics- Income Tax Act- Section 83- Subsection 83(2.1) “main” has a connotation of importance A British taxpayer (TDS) used a total return swap to cause its share investment in a subsidiary (LGI) to be deemed to be a loan. ... After so concluding against TDL, Lord Justice Newey stated (at para. 48): I would add, however, that I do not accept that, as was submitted by Mr Ghosh [for HMRC], "main" … means "more than trivial". ...

Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794-- summary under Agency Summary Under Tax Topics- General Concepts- Agency a placement service providing non-employee temps to clients was not paying the temps’ compensation on the clients’ behalf An employment bureau (Adecco) introduced temporary staff ("temps"), who were not Adecco employees, to clients looking for a temporary worker to undertake an assignment, and if the temps accepted an assignment, Adecco paid them for the work they did for the clients – and collected those amounts plus a mark-up from the clients. ...

Hill & Anor. v. C. & E. Cmners., [1988] BTC 5139 (QBD)-- summary under Agency Summary Under Tax Topics- General Concepts- Agency A commercial gallery successfully argued that it was selling pottery as agent for some potters, rather than as principal. ...

Royal National Institute for the Blind & Ors, [2014] BTC 24, [2014] EWHC 1373 (Ch)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission specific intent to accomplish a particular devise at the time of botched drafting The claimant applied for rectification of a Deed of Variation which altered the provisions of the will of Hilda Bolton with a view to reducing the incidence of inheritance tax, pursuant to s. 142 of the Inheritance Tax Act 1984, which permitted the effecting a deed of variation within two years of the date of death in order to redirect gifts passing under a will. ...