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., 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. ...

Commissioners for HM Revenue and Customs, [2013] UKSC 26, [2013] WLR (D) 172-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission mistake re tax consequences justified rescinding settlement of trust The claimant had settled the moneys received as damages for injury to her husband on a discretionary trust of which she and others were trustees. ...

A.G. of Canada, 2015 ONSC 6245-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission reorganization of corporate structure to reflect what it was thought to be at the time of making a tax election The Telus group had a tiered partnership structure. ...

Re Razzaq Holdings Ltd (2000), 11 BLR (3d) 157, 2000 BCSC 1829-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission In 1992 the two shareholders of a corporation purported to transfer a total of 100 Class A shares and 100 Class B shares equally to two holding companies. ...

Canada (Attorney General), 2012 NSSC 217-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission proposed rectification inconsistent with financial statements The applicant, incorporated by a U.S. corporation ("Fidelity National"), received $23,659,000 from Fidelity National in order to finance its business in Nova Scotia. ...

Canada (Attorney General), 2009 CanLII 18234 (Ont SC)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission unopposed application to reduce capital dividend to CDA balance The directors of the taxpayer mistakenly declared a dividend in an amount exceeding its capital dividend account, and it elected under s. 83(2) to treat it as capital dividend. ...

Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission transaction documents rectified because they did not implement the parties' intention to not trigger Part IV tax Four individuals held their indirect holdings of 10%, 10%, 5% and 5% of the common shares of a Canadian-controlled private corporation (Structures) through three holding companies (the "Holdcos"). ...

Samarkand Film Partnership No. 3 & Ors v Revenue and Customs, [2017] EWCA Civ 77-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business non-trading business At issue was whether two partnerships which acquired interests in films and immediately leased their acquired interest for fixed, increasing, secured and guaranteed rental payments for a 15 year period, and were acknowledged to have a business, were carrying on a trade. ... " In affirming the finding below (initially made by the First-Tier Tribunal) that the partnerships were not carrying on a trade, Arden LJ stated (at paras 59, 61, 66): … [I]t is now clear from Eclipse … that the question whether what the taxpayer actually did constitutes a trade has to be answered by standing back and looking at the whole picture…. … The [FTT’s] overall assessment of the commercial nature of the agreements as the payment of a lump sum in return for a series of fixed payments over 15 years…was not a crude conclusion based on an impermissible transformation of the taxpayers' activities into an economic equivalent, but rather a way of expressing the ultimate inference of fact which they drew from the totality of the primary facts which they had found. ...