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TCC (summary)
Borealis Geopower Inc. v. The Queen, 2018 TCC 189 (Informal Procedure) -- summary under Payment & Receipt
The Queen, 2018 TCC 189 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt taxpayer had "physically" received govenment assistance funds with freedom to transfer Although all the conditions for the receipt of government assistance had not yet been (and never were) satisfied, Campbell J found that the taxpayer had “physically acquired” the funds in question through depositing a cheque to a trust account of its own formation and thereafter disbursed the funds out of the account to fund its project without any practical hindrance by the government foundation in question (which appeared to have waived the condition referred to above). ...
TCC (summary)
Black v. The Queen, 2019 TCC 135 -- summary under Payment & Receipt
The Queen, 2019 TCC 135-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt advance on another party’s behalf established a loan The taxpayer (“Black”) controlled both Hollinger Inc. ...
EC summary
Moody v. MNR, 57 DTC 1050, [1957] CTC 110 (Ex Ct) -- summary under Payment & Receipt
MNR, 57 DTC 1050, [1957] CTC 110 (Ex Ct)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt cheque generally payment when received In finding that cheques that a cash-basis farmer had on hand at the beginning of the year were income in the previous year when they had been received, rather than in the current year, Thurlow J stated (at p. 1054): In the absence of some special circumstance indicating a contrary conclusion such as, for example, post-dating or an arrangement that the cheque is not to be used for a specified time, a payment made by cheque, although conditional in some respects, is nevertheless presumably made when the cheque is delivered and, in the absence of such special circumstances, there is, in my opinion, np ground for treating such a payment other than as a payment of cash made at the time the cheque was received by the payee. ...
News of Note post
11 November 2020- 11:18pm Yellow Point – Federal Court of Appeal confirms that an ecological gift was made in the year before it was certified as such Email this Content A taxpayer, who donated an interest in ecologically sensitive land to two qualified donees in 2008, unsuccessfully argued that the gift was not made until 2009 for purposes of computing the five-year (now 10-year) carryforward period described in s. 110.1(1)(d)(iii), because it was not until 2009 that he received the certification from the Minister of the Environment as to the land's ecologically sensitive nature and value that was required under that provision. In confirming that the ecological gift instead was made in 2008 when the gifted property was transferred, Noël CJ stated: [W]hen property is gifted … the disposition takes place when ownership of the gifted property is transferred from the donor to the donee … … There is no doubt that the appellant’s entitlement to the capital gain exemption and the related deduction did not arise until 2009 when all the conditions set out in paragraph 110.1(1)(d) and subsection 110.1(2) were met, but this does not alter the time when the “gift was made”. Noël CJ also effectively found that the word “peut” (may) in the French version of s. 118.1(11) meant the same thing as the word “shall” in the English version, stating in this regard: [T]he use of the word “peut” in the French version illustrates how “an official who is permitted to do a thing may, in addition, be obliged to do it” (Ruth Sullivan, Sullivan on the Construction of Statutes …). ...
Technical Interpretation - External summary
25 July 2019 External T.I. 2018-0787011E5 - Spousal support - legal expenses & lump-sum awards -- summary under Legal and other Professional Fees
This would be the case as long as the support claim is bona fide and … with a reasonable chance of success, and even if the claim for support is unsuccessful …. Conversely, where an individual starts a support claim for the purpose of collecting a lump-sum payment that does not qualify as a support amount …, the individual is not entitled to deduct legal and accounting fees incurred for that purpose. Assuming that the support claim … was started to establish or collect support amounts … no adjustments to the individual’s prior years’ tax returns would be warranted to exclude the legal expenses previously deducted in computing the individual’s income. ...
News of Note post
The relevant QSTA provisions, which were broadly similar in this regard to ETA ss. 225(1) – A(a), 228(2) and 222(1), required that a person receiving payment of a policy premium collect the tax thereon as agent for the Minister and remit such tax to the Minister. ... In going on to confirm the imposition of penalties on the taxpayers pursuant to the Tax Administration Act (generally calculated as 15% of the amounts they had remitted one month late), the Court stated: The defence of due diligence allows for the avoidance of administrative penalties imposed by a statute where an error of fact is made in good faith, but not where there is an error of law. … … To allow the taxpayer to escape the consequences of failing to meet its obligations by proposing a different interpretation of the legislative provisions would open a loophole that is difficult to reconcile with [the self-assessment] principle. ... Assurances générales Desjardins Inc., 2022 QCCA 57 under ETA s. 225(1) – A(a) and ITA s. 227(8)(a). ...
News of Note post
28 March 2022- 11:45pm Shaker – Federal Court finds that a trustee of a real estate trust does not hold any “interest in real property” that can be charged by CRA Email this Content CRA obtained an interim order to charge the interest of Mr. ... Shaker’s legal interest in the Blue Jays Way property as trustee, and before ordering the interim charge to be discharged, Walker J stated: Trust property is not available to the creditors of a trustee where the debt in question is the trustee’s personal debt …. ... To conclude otherwise would improperly and adversely impact the interests of the third-party beneficiaries of the VSI Trust. … … Canada North Group stat[ed] “[p]roperty held in trust cannot be said to belong to the trustee because ‘in equity, it belongs to another person’ (Henfrey [[1989] 2 S.C.R. 24]], at p. 31)”. ...
News of Note post
29 September 2016- 9:25pm Chriss – Federal Court of Appeal finds that a written resignation must be signed and delivered to the corporation to start the two-year s. 227.1(4) period running Email this Content The husband of a director had instructed their law firm to prepare a written resignation for her, which they did, but the resignation form was never provided to her. In reversing a finding of Boyle J that this was sufficient to amount to a written resignation that started the two-year limitation period in s. 227.1(4) running, Rennie JA stated: …In the absence of the communication of a written resignation to the corporation, a resignation is not effective. … … Reliance on the subjective intention or say-so of a director alone would allow a director to plant the seeds of retroactive resignation, only to rely on it at some later date should a director-linked liability emerge. ...
Current CRA website
Line 25500 – Prescribed Zones – Yukon, Nunavut, and the Northwest Territories
Line 25500 – Prescribed Zones – Yukon, Nunavut, and the Northwest Territories If you live in a place that is not listed below and you think you live in a prescribed zone, contact the Canada Revenue Agency. Yukon, Nunavut, and the Northwest Territories Table of the prescribed northern zones for Yukon, Nunavut, and the Northwest Territories Zone A – Prescribed Northern Zones All places in the Yukon, Nunavut, and the Northwest Territories are located in a prescribed northern zone. ...
News of Note post
24 June 2019- 12:57am Black – Tax Court of Canada finds that an ancillary income-earning purpose for making a loan whose terms were never finalized was sufficient to satisfy s. 20(1)(c)(i) Email this Content Conrad Black controlled both Hollinger Inc. ... Rossiter CJ accepted Black’s position that the borrowed money had been used by Black to make a loan to Inc., so that Black was entitled to an interest deduction on his borrowed funds, stating: … Black and Inc. reached an agreement on the essential terms of the loan and left the details to be worked out at a later date. The fact that a formal document outlining those essential terms was to be prepared later on and signed … does not alter the validity of the earlier contract. … Since Black had an obligation to pay interest expenses on the Quest Loan, Black had to earn interest income on the loan to Inc. in order for him to be made whole. … … While I find that this was an ancillary purpose compared to his primary purpose of helping Inc., that was a bona fide objective of his investment, which is capable of providing the requisite purpose for interest deductibility under paragraph 20(1)(c). ...