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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 …. ...

. … She registered for the summer semester and paid a single fee. All courses were taken consecutively or “one after the other”, over a ten week semester. ...

., address for invoicing and of electricity use, late payment identification and telephone number) for all its commercial customers who were charged the regular electricity rate – so that CRA could compare this information with what it had in its own files. ...

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

Graham J accepted the submission of the applicants (the designated partners of the partnerships) in connection with a Rule 58 determination that the Minister could not issue a valid Notice of Determination if the Minister had concluded that the partnership in question did not exist – so that the Notices of Determination were invalid. ...

The corporation then sold this middle lot to an individual purchaser coupled with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

The corporation then sold this middle lot to an individual purchaser couple with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

. … The argument put forward by Bowman that they are “nothings” for Canadian tax purposes because they are merely reputational payments arising in a non-business circumstance may ultimately be upheld by the Tax Court, but it is not so clear at this stage as to render the CRA’s position unreasonable. ...