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. … The submission, dated two weeks after the notice of reassessment, while not perfectly detailed, was sufficient to initiate the objection process responsive to an audit and conclusions already in active dispute. ...

Had he believed he was not a shareholder of HGSL as of that date, he could have applied to rectify the register under section 168 of the NBBCA …. ...

Unfortunately, s. 56(1)(u)(ii) deemed the ODSP payments to be the income of the higher-income spouse (herself) – so that on a literal reading of the combined effect of s. 122.62(5)(b) and s. 56(1)(u)(ii), her family income included not only her actual income but also the income attributed to her under s. 56(1)(u)(ii). ...

The King, 2023 TCC 173 (Informal Procedure)-- summary under Qualifying Group Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Group three corporations wholly-owned by an individual could not make a s. 156 election In finding that three corporations which had the same individual as their sole shareholder did not qualify as specified members of a qualifying group, so that they were ineligible to make the joint election pursuant to s. 156(2), Jorré J noted that, in the case of corporations, the “qualifying group” definition referred to ”a group of corporations, each member of which is closely related … [per s. 128] to each other member of the group,” and then stated (at paras. 17-18, TaxInterpretations translation): In accordance with section 128, only corporations controlled by a corporation may be closely related. ...

Goyette JA found that the Tax Court had failed to recognize that the redemption amounts, although paid in the course of PC Bank’s exempt financial services business, were also paid in the course of its commercial activity of “driving customers to Loblaws” – and that it did not matter that PC Bank was incurring a loss on this commercial activity because a commercial activity of a corporation was not required to have a reasonable expectation of profit. ...

Canada, 2024 FCA 192-- summary under Certainty Summary Under Tax Topics- Statutory Interpretation- Certainty Parliament seeks certainty, predictability and fairness In rejecting a submission of the taxpayer that s. 161(7)(b)(iv) was inapplicable to the computation of interest in the situation where its request to carryback a loss to an earlier year was in response to a proposed audit adjustment for the earlier year rather than the situation of a carryback request not being prompted by an unforeseeable adjustment, Woods JA found that, given that “Parliament seeks certainty, predictability and fairness in tax legislation … [i]f Parliament did not intend to impose interest when a loss carryback is claimed as a result of an audit adjustment, it is likely that Parliament would have provided for this with explicit language” (para. 39). ...

In finding that these distributions did not entail the taxpayer giving consideration to the trust for s. 160 purposes, Gagnon J found that: “the trustee's distributions had no impact on the rights of a beneficiary of the Trust who had or had not received a distribution” (para. 65, TaxInterpetations translation); and although the taxpayer “had a right under the Trust to be considered by the trustee for any distribution on the same basis as the other beneficiaries … there is no reason to believe that anyone would have paid even a very small amount for [this right]” and “[i]n fact, it is highly unlikely that such a right could be transferred to a third party” (para. 67). ...

ARQ, 2025 QCCQ 1330-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA The ARQ assessed the taxpayer within two years of the taxpayer’s dissolution pursuant to s. 210(3) of the CBCA. ...

However, the Minister had not pleaded backdating- only that the appellant had continued as a director – nor did she plead lack of due diligence. ...

After finding that the taxpayers were not ordinarily resident in Canada, Boyle J. found (at para. 43) that this factual situation "clearly meets the intermittent, temporary visit or stay parts of the meaning given to sojourn... in Thomson " and that "a business trip is one of the specific examples set out by Professors Hogg and McGee of sojourning. ...