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Decision summary
Halsall & Ors v Champion Consulting Ltd & Ors, [2017] EWHC 1079 (QBD) -- summary under Negligence, Fiduciary Duty and Fault
Halsall & Ors v Champion Consulting Ltd & Ors, [2017] EWHC 1079 (QBD)-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault knowledge that advice – that investing in a tax shelter was a “no brainer”- was negligent, accrued when HMRC started investigating The claimants, who were non-tax solicitors, claimed that they had been negligently induced by the defendant accounting firm (“Champion LLP”) and an associated corporation (“Champion Consulting”) to invest in two tax schemes referred to as the "charity shell" and "Scion" film schemes. ... The fact that some of the companies succeeded and that some of the schemes went unchallenged by the Revenue is in my view irrelevant to the question of whether the reasonably competent tax adviser would have given an unconditional assurance that the charity shell scheme would work effectively. … [T]he failure … lay in not explaining that the valuation was pivotal to the success of the scheme and how this wide range of companies could all be valued at four times the initial subscription and this failure amounted to a breach of duty. ... With respect to the Scion film schemes, Moulder J found (at paras. 318, 319 and 335): … [I]t seems to me that the defendant did not advise that the claimant could lose more than their initial contribution. … The evidence is clear that the defendants did not point out the risk of the additional liability arising out of the outstanding loan and exposure to a tax charge in the event of the loan being written off. … [I]n my view the advice of Ms Molloy [an accountant and chartered tax advisor] that the prospects of success of the film scheme were 75% was outside the range open to her and amounted to a breach of duty being advice such as no reasonably well-informed and competent member of that profession could have given. ...
Technical Interpretation - Internal summary
10 June 2019 Internal T.I. 2019-0796221I7 F - Qualification d’un véhicule à titre de « voiture de tourisme » -- summary under Automobile
10 June 2019 Internal T.I. 2019-0796221I7 F- Qualification d’un véhicule à titre de « voiture de tourisme »-- summary under Automobile Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Automobile a passenger vehicle ceases to qualify as such when it commences to be used as a taxi given the s. 13(7)(b) deemed acquisition When asked as to the qualification of a vehicle as a "passenger vehicle” where it initially was acquired for personal use and subsequently began to be used primarily as a taxi, CRA noted that this definition turned on that of "automobile," which excluded a motor vehicle acquired primarily for use as a taxi and that, by virtue of a deemed acquisition under the change of use rules in s. 13(7), the “acquired primarily for use as a taxi” condition is satisfied on the change of use. ...
Decision summary
Travel Document Service & Ladbroke Group International v Revenue & Customs (Rev 1), [2018] EWCA Civ 549 -- summary under Interpretation/Definition Provisions
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. ...
Decision summary
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber) -- summary under Paragraph 12(1)(c)
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The son of the taxpayers (Mr and Mrs Pope), who was the beneficiary of a life insurance policy which he had purchased on his own life, was abducted in Angola by rebels in 1998. ...
Decision summary
Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794 -- summary under Consideration
Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration consideration for temps included their remuneration The appellants ("Adecco") were employment bureaux supplying clients with temporary staff ("temps") who were not employees of Adecco. ...
Technical Interpretation - External summary
23 January 2023 External T.I. 2020-0865161E5 F - SSUC/CEWS – Sous-alinéa 125.7(4)e)(i) et personne -- summary under Payment & Receipt
23 January 2023 External T.I. 2020-0865161E5 F- SSUC/CEWS – Sous-alinéa 125.7(4)e)(i) et personne-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt a cash-basis taxpayer can receive an amount when it is received through a third party When is an amount regarded as received by an eligible entity which has made an election under s. 125.7(4)(e)(i) to use the cash method in determining its qualifying revenues for CEWS purposes, where the amount is received by a third party before being paid to the eligible entity? CRA indicated that in this regard it would apply the principle in IT-433R, subpara. 3(a) that the meaning of the term "received" is broad enough to consider a taxpayer to have received an amount where it “was received by a person authorized to receive it on behalf of the taxpayer” – and further stated that “a person entitled to receive an amount on behalf of a taxpayer for CEWS purposes may include a person who is entitled to receive the amount for a taxpayer by inter alia an agreement or by statute.” ...
Decision summary
C. & E. Commissioners v. Faith Construction Ltd., [1989] BTC 5121 (C.A.) -- summary under Payment & Receipt
& E. Commissioners v. Faith Construction Ltd., [1989] BTC 5121 (C.A.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt even though obligation to lend back In response to the proposed repeal effective 1 June 1984 of the zero rating of building alteration services, four building companies with existing contracts for building alterations arranged with their customers for payment by the customers before that date subject (in one case) to the condition that the building company would immediately lend back an equivalent sum, to be repaid as the work was done or subject (in the other case) to that money being paid into an account of the building company for release only as the work was done. ...
Administrative Policy summary
GST/HST Audit and Examination Manual, 9 – Taxpayer Rights and Taxpayer Relief – 9.1.6.3 “ The right to privacy and confidentiality -- summary under Subsection 295(5)
GST/HST Audit and Examination Manual, 9 – Taxpayer Rights and Taxpayer Relief – 9.1.6.3 “ The right to privacy and confidentiality-- summary under Subsection 295(5) Summary Under Tax Topics- Excise Tax Act- Section 295- Subsection 295(5) Informal request in lieu of ATIP request When an access to information and privacy (ATIP) request is received, the Access to Information and Privacy Directorate of the Public Affairs Branch forwards the request to the appropriate party(ies) to obtain the relevant information. ... Permitted scope of informal request Some examples of information that can be released to a registrant or authorized representative under an informal request include: • the T20 Report • external and internal correspondence, including memoranda, appropriately severed where necessary • related correspondence with Headquarters such as technical interpretation requests or opinions and referrals to specialized sections about a specific person • working papers, excluding third-party information, leads, disclosure of audit techniques, and information from informants • related reports from external and internal valuators, appraisers and electronic commerce audit specialists, • severed versions of operations manuals available to the public Examine the documents before releasing them to ensure no confidential information about a third party is released. Prohibited disclosures Examples of information that cannot be released are: • information obtained in confidence during an audit or examination that may prejudice the results of the audit or examination, such as Criminal Investigation reports, Royal Canadian Mounted Police reports, or documents obtained as part of an investigation • audit techniques and specific audit guidelines • information about investigations in process when a decision is pending • documents of a related file under investigation • confidential information about another registrant • Department of Justice correspondence and information under solicitor-client privilege, including legal opinions from the Legal Services Branch (for more information, go to Disclosing legal opinions and Use of legal opinions inside the Agency) • specific advice and recommendations developed by or for a government institution or minister of the Crown that may restrict the CRA's ability to administer the ETA if they are disclosed • accounts of consultations and deliberations involving officials or employees of a government institution or a minister of the Crown that may reasonably be expected to cause injury or restrict the CRA's ability to administer the ETA if disclosed • information released to a third party, other than specifically permitted by paragraph 295(5)(d) of the ETA or where consent is given by the registrant • copyright material • computer printouts from CRA computer systems. ...
SCC (summary)
Performance Industries Ltd. v. Sylvan Lake Golf & Tennis Club Ltd., 2002 SCC 19, [2002] 1 SCR 678 -- summary under Rectification & Rescission
Sylvan Lake Golf & Tennis Club Ltd., 2002 SCC 19, [2002] 1 S.C.R. 678-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification available notwithstanding lack of due diligence on part of plaintiff The plaintiff (“Sylvan”) and the defendant (“Performance”) entered into an agreement respecting a golf course that gave Sylvan the option on the 18 th fairway for a specific residential development to be undertaken by it. ... The plaintiff must establish that the terms agreed to orally were not written down properly. … What is essential is that at the time of execution of the written document the defendant knew or ought to have known of the error and the plaintiff did not. ...
TCC (summary)
Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163, [1992] 1 CTC 2218 (TCC) -- summary under Payment & Receipt
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. ...