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In his dissenting reasons, Pelletier JA referred inter alia to s. 67(2) of the Bankruptcy and Insolvency Act, which reflected an intention that “Parliament put the Crown on the same footing as unsecured creditors” in a bankruptcy” – with an exception for employee source deductions, which “is explained by the fact that source deductions are amounts which belong to the employee in question…[and] this money does not belong to the employer anymore” (paras. 73-74). ...

. … The gravamen of the offence under subsection 163(2) is making of a false statement, knowing (actually or constructively, i.e., through wilful blindness) that it is false. ...

In my view, in the circumstances of this case, [the appellants] had sufficient common interest in the transactions to warrant a finding that, in Alberta or British Columbia, the … memo is protected from disclosure by solicitor-client privilege. ...

Canada, 2018 FCA 74-- summary under Tax Benefit Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(1)- Tax Benefit tax benefit to trust from tax-free dividend even though not distributed to a beneficiary In order to strip surplus of an operating corporation (“Gennium”) controlled by the Pilon family, a dividend paid by Gennium was distributed through a series of transactions to a corporation with no assets (“9163”), which then paid the amount to a Pilon family trust (“Satoma Trust” – which also had a corporate beneficiary) as a dividend on special shares that Satoma Trust held in 9163. ...

Canada, 2018 FCA 121-- summary under Subsection 248(28) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(28) potential for double taxation under the ITA of NAL transactions The taxpayer, a Canadian exploration company, unsuccessfully argued that it was not subject to Part XII.6 tax on Canadian exploration expenses (“CEE”) that it had purported to renounce under the look-back rule- but which were now admittedly not eligible for look back because the flow-through share investors were non-arm’s length – because the reference in Part XII.6 to CEE that it “purported” to renounce under the rule referred only to expenses which had been validly rather than invalidly renounced under the look-back rule. ...

. $19M in fees paid to a French lobbyist firm, whose purpose “was to facilitate the implementation of the Pechiney transaction by heading off possible political and public relations issues which might derail the transaction, given Pechiney’s special status … in France” (para. 29), fell into the implementation cost category, and were capital expenditures. ...

He was aware of the hedging effect which the Forward Contract would have on the BNS shares …. ...

Its jurisdiction does not extend to judicial review of decisions of the Minister under discretionary relief provisions of the Act …. ...

., 2018 FCA 166-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) s. 103(1) likely applies to the allocation of most of the partnership profits at year end to a lossco that never had significant economic interest or risk in the partnership business Income account treatment of the profits realized by a condo-project limited partnership was avoided by the corporate partners (the Partnercos) of the partnership paying safe income dividends (out of the realized but unallocated condo profits) to their respective Holdco shareholders through the payment of stock dividends of preferred shares followed by a redemption of those preferred shares – in turn, followed by a sale by the Holdcos of the Partnercos to a public company with substantial resource pools (Nuinsco). ...

After finding that the value-shift transactions entailed an avoidance transaction given that their professed estate-freezing purpose could have been accomplished more conventionally (utilizing a s. 85(1) or 86(1) rollover), Noël CJ went on to find that they were an abuse of the basic capital gains provisions (ss. 38(b), 39(1)(b) and 40(1)(b)), stating (at para. 56, TaxInterpretations translation): [I]t is possible for the object and spirit of provisions in issue to have a larger rationale that that which emerges on a reading based on the words (See … Triad Gestco, paragraph 51). ...