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Decision summary
Barlis 06 - Investimentos Imobiliários e Turísticos SA v. Autoridade Tributária e Aduaneira, [2016] EUECJ C-516/14 (European Court of Justice (Fourth Chamber)) -- summary under Subsection 169(4)
…[T]he authorities … must also take account of the additional information provided by the taxable person. ...
Decision summary
Chevron Australia Holdings Pty Ltd v Commissioner of Taxation, [2017] FCAFC 62 -- summary under Retroactivity/Retrospectivity
. … That a person may not be aware at an earlier point in time what the criteria of liability may subsequently be made to apply to that earlier point in time does not make the legislation arbitrary or incontestable…. ...
FCA (summary)
High-Crest Enterprises Limited v. Canada, 2017 FCA 88 -- summary under Government Funding
. … Also paragraph 191.1(2)(c) of the ETA is a condition that, if satisfied, will result in certain consequences under the ETA. ...
TCC (summary)
Mady v. The Queen, 2017 TCC 112 -- summary under Subparagraph 69(1)(b)(i)
. … The [wife and children] acquired the shares from the Appellant for a purchase price of $0.01 per share and immediately thereafter sold them for a cash purchase price of $8,645 per share. ...
TCC (summary)
Grant v. The Queen, 2017 TCC 121 -- summary under Paragraph 227.1(2)(c)
Finally, Smith J found (at para 58): As indicated… in Kyte … there may be discrepancies as the amounts owed for source deductions may be fluid. ...
FCA (summary)
Canada v. Callidus Capital Corporation, 2017 FCA 162, rev'd 2018 SCC 47 -- summary under Subsection 222(1.1)
. … Accordingly, Callidus was liable to the Crown under s. 222(3) for its pre-bankruptcy breach of the s. 222(1) deemed trust. ...
TCC (summary)
Aon Inc. v. The Queen, 2017 TCC 166 -- summary under Improvements v. Repairs or Running Expense
. … However, the new replaced area of the roof, half the roof, is inseparable from the floor of the garage below it and from the entire garage. ...
TCC (summary)
Cassan v. The Queen, 2017 TCC 174 -- summary under Subsection 143.2(12)
. – of which 3.75% of p.a. was required to be paid annually in cash (“cash-pay interest”) and with the balance was capitalized each year (“capitalized interest”). ...
Decision summary
Google Ireland Ltd. v. France (2017), No. 1505113/1-1 (Tribunal Administratif de Paris) -- summary under Article 5
The Court concluded (at para. 16, TaxInterpretations translation): [I]f SARL Google France had the character of dependent agent within the meaning of (c) of paragraph 9 of Article 2 of the French-Irish Tax Convention, it nonetheless did not exercise, in the years under litigation, the power to bind Google Ireland Limited in commercial relations respecting the transactions constituting the activities of the latter corporation; it follows from this that the Service was incorrect in considering that Google Ireland Limited exercised, through a permanent establishment that was formed by SARL Google France, an activity in France within the meaning of section 182 of the General Income Tax Code …. ...
Decision summary
Lewski v Commissioner of Taxation, [2017] FCAFC 145 -- summary under Subsection 104(24)
It follows that, assuming that each ‘variation of income’ resolution was authorised by the relevant trust deed, the applicant was not “presently entitled” to a share of the net income of the trust estate … for [that] year…. ...