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8 June 2014- 11:28pm Francis & Associates – Tax Court of Canada finds that substantively-correct bad debt deductions cannot be claimed in an amended return Email this Content Due to problems with its accounting system, a law firm did not discover until late in 2005 that billings made in 2002 to 2004 and which had become bad in those years had not been written off in the accounts.  ... Summary of Francis & Associates v. The Queen, 2014 DTC 1146 [at 3468], 2014 TCC 137 under s. 20(1)(p)(i). ...

17 December 2019- 12:03am Dow & Duggan – Tax Court of Canada finds that CRA does not have the discretion to stipulate the documentary requirements for direct-shipment export zero-rating Email this Content Sched. ... Summaries of Dow & Duggan Log Homes International (1993) Limited v. ...

25 June 2015- 10:41am GMAC Leaseco – Tax Court of Canada finds that an amount received subject to future adjustment was unearned – but, by the same token, it was not “received” for s. 12(1)(x) purposes Email this Content GMAC received "support payments" from GMC in order to inflate the residual values stated in its leases of cars to GMC customers, thereby reducing the lease payments but resulting in a likely loss on lease termination.  ... The Queen, 2015 TCC 146 under s. 9 – timing, s. 12(1)(x), s. 9 – compensation payments, s. 9 – computation of profit, s. 18(1)(a) – timing. ...

18 October 2017- 1:13am Plains Midstream – Tax Court of Canada finds that s. 16(1) operates symmetrically (no creditor interest – no debtor interest deduction) Email this Content To over-simplify somewhat, Amoco agreed to assume a $225M loan that was due in perhaps 43-years’ time and that was effectively non-interest-bearing (or more precisely, only bore interest to the extent of oil production from the Beaufort Sea) in consideration inter alia for the payment to it of $17.5 million by the debtor. ... In denying any interest deduction, he stated: The language used in subsection 16(1) of the ITA stating that the payment is “deemed to be interest on a debt obligation held by the person to whom the amount is paid or payable” reflects Parliament’s intention that both parties receive symmetrical treatment. … [N]o part of the amount that is due by the Appellant can reasonably be regarded as interest that is payable to APCJ under the terms and conditions of the … loan. … [I]t is unthinkable that Parliament would have intended the asymmetrical treatment proposed by the Appellant as this would open the door to transactions in which one party receives a tax benefit and the other party receives a non-taxable payment, resulting in a one-sided tax expenditure. ... The Queen, 2017 TCC 207 under s. 16(1) and s. 54 – adjusted cost base. ...