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Canada (Attorney General), 2025 ONCA 65-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission capital dividends were agreed to be paid in amounts that overlooked a CDA deficit: no rectification A plan was implemented for successive capital dividends to be paid up a chain of corporations so that the individual who was the ultimate shareholder could have a tax-free receipt of $1.4 million. ... …The corporate resolutions that were signed … accurately reflect the agreement. ...

Juliar, 2000 DTC 6589, 50 OR (3d) 728, 2000 CanLII 16883 (Ont CA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The Court confirmed the decision of the trial judge, to rectify an agreement for the transfer by the appellants of half the shares of a company to a newly-incorporated holding company so as to reflect consideration that was treasury shares of the holding company rather than promissory notes, on the basis of the trial judge's finding that "the true agreement between the parties here was the acquisition of the half interest... in a manner that would not attract immediate liability for income tax" and a finding that the parties would have chosen to receive shares but for the mistaken belief of the advising accountant that the transferred shares had full cost base. ...

The Queen, 2011 DTC 1216 [at at 1274], 2011 TCC 289-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment through back-to-back promissory notes In settlement of a suit by the taxpayer, who was an income beneficiary, the settlement agreement provided for the payment by the trust to her of $1.7 million in satisfaction of her interest in the trust. ...

No. 1238, 2010 ONCA 233-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission corporation included in amalgamation based on mistake The applicant resulted from several corporations being amalgamated in order that the tax losses of some of the predecessor corporations could be accessed. ...

Canada, 2012 DTC 5042 [at at 6770], 2012 BCSC 132-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission 2nd rectification to avoid s. 75(2) taint The petitioners were trustees of a family trust which had been formed in order to permit capital gains on any subsequent sale of the shares of the private company with which the trust had been settled to be allocated amongst the children beneficiaries, thereby multiplying the utilization of the capital gains exemption. ...

.)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The Minister assessed the applicant, a mutual fund manager, on the basis that a payment to it by mutual funds of deferred sale charges received by the mutual funds from redeeming investors represented consideration for taxable supplies of services made by the applicant to the mutual funds. ...

Bramco Holdings Co. (1995), 21 OR (3d) 739 (CA), aff'g (1994), 17 OR (3d) 571 (Gen Div)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rewriting fiscal history Ontario farm lands were transferred to a non-resident corporation for the purpose of utilizing losses of that corporation. ...

., 2012 DTC 5052 [at at 6814], 2012 ONSC 549-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission declaration re character of Ponzi amounts received The applicants and the respondents (which were corporations held by the applicants) were defrauded in a Ponzi scheme. ...

Slipacoff, 2010 ONSC 2693-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission two-year limitations period The defendant and plaintiff held shares in an incorporated dental practice. ...

Minister of Finance, 2008 CanLII 15226 (Ont SCJ), briefly aff'd 2009 ONCA 715-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission A transfer of tangible personal property by an Ontario corporation ("1006") to a second corporation ("QL") would have been exempt from Ontario retail sales tax if QL were a wholly-owned subsidiary of 1006 at the time of the transfer. ...