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Offshore Compliance Advisory Committee – Minutes – June 15, 2016
Offshore Compliance Advisory Committee – Minutes – June 15, 2016 Wednesday, June 15, 2016 Inaugural Meeting List of Participants OCAC Members Chairperson Colin Campbell Vice-Chair Kimberley Brooks Committee Members Marie-Pierre Allard Catherine Brown Larry Chapman Allan Lanthier Daniel Thornton CRA Attendees Minister of National Revenue The Honourable Diane Lebouthillier Assistant Commissioner, International, Large Business and Investigations Branch Ted Gallivan Deputy Assistant Commissioner, International, Large Business and Investigations Branch Lisa Anawati Director, Horizontal Programs Division Joanne Heidgerken Manager, Voluntary Disclosures Program Kevin Morgan Director General, Criminal Investigations Directorate Johanne Charbonneau Director, Criminal Investigations Division Stephane Bonin Acting Director General, International and Large Business Directorate Jennifer Ryan Director, Offshore Compliance Division Gina Jelmini Special Advisor, International, Large Business and Investigations Branch Maria Pagliarello Special Advisor, International, Large Business and Investigations Branch Alexandra MacLean Senior Technical Advisor, International and Large Business Directorate Maureen O'Leary 1. ...
In rectifying this redemption to treat it instead as a loan by FHIW Canada to its parent, Newbould J found that there had been a continuing intention for the reciprocal loan arrangement to be tax neutral, and that "the purpose of the … unwind of the loans was not to redeem the preference shares of FHIW Canada … but to unwind the loans on a tax free basis. ... Simmons JA stated that " Juliar … does not require that the party seeking rectification must have determined the precise mechanics or means by which the party’s settled intention to achieve a specific tax outcome would be realized," so that it was sufficient that Fairmont’s "settled tax plan" at the time was to achieve "tax neutrality in its dealings with Legacy and no redemptions of the preference shares. ... Canada, 2015 ONCA 441 under General Concepts – Rectification. ...
BCSC decision
Her Majesty the Queen in Right of the Province of British Columbia v. Her Majesty the Queen in Right of the Province of British >>columbia as Represented by the Minister of Labour and Consumer Services, Employment Standards Branch, and Her Majesty the Queen in Right of Canada, Revenue Canada, Taxation, [1991] 1 CTC 523
Subsection 15(2) provides that “ Notwithstanding any other Act, the amount of a lien and charge and secured debt referred to in subsection(s) (1)...is payable and enforceable in priority over all liens, judgments, charges or any other claims or rights including those of the Crown in the right of the Province...”. ... While the Court of Appeal held that section 224 was a garnishment provision, it was clear in its reasoning that nothing in that section “ (had) the effect of transferring the property of the funds to the Minister or establishing a priority of Revenue Canada's claim”. ...
T Rev B decision
Vir K Handa, Appellant, >>minister of National Revenue, Respondent., [1978] CTC 2256, 78 DTC 1191
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News of Note post
14 November 2022- 11:59pm 1410109 Ontario – Tax Court of Canada finds that a “gratuity” that was required to be paid was subject to HST Email this Content The contract of an incorporated banquet hall with its event customers stipulated: “All Pricing is Subject to 13% HST and 15% Gratuities.” ... He dismissed the taxpayer’s appeal, on the basis that the gratuities were not voluntary, stating: Subsection 133(b) combined with subsection 138(a) … suggests that tips included in an agreement are part of the overall supply of prepared meals, which is subject to HST. … The ETA defines “consideration” as “any amount that is payable for a supply by operation of law.” ... The King, 2022 TCC 141 under ETA – 123(1) – consideration. ...
News of Note post
Boivin JA noted that: “The Judge recognized that the CRA investigators owed the appellants a duty of care … but found that the investigation was not carried out in a manner that could be characterized as negligent and was not motivated by malice or any other improper purpose”. ... Boivin JA found “no reason to disturb the Judge’s findings” – their appeal was dismissed. ... The King, 2023 FCA 12 under General Concepts – Negligence & Fault. ...
25 April 2016- 7:34am Wesdome Gold Mines – Cour du Québec finds that a mine on care and maintenance was a closed mine for CEE purposes Email this Content A company (”Wesdome”) acquired the Kiena mine in Quebec, which had been put on care and maintenance when its reserves had been exhausted over a year earlier, in order that it could extend an existing mine shaft to go under a lake and drill gold targets on its own exploration property to the north. ... ARQ denied CEE deductions under the Quebec equivalent of ITA, s. 66.1(6) – Canadian exploration expense – (c)(vi), which applied to “any expense that may reasonably be related to a mine…that has come into production in reasonable commercial quantities or to an actual or potential extension of such a mine.” ... ARQ, 2016 QCCQ 1504 under s. 66.1(6) – Canadian exploration expense – (c). ...
News of Note post
16 May 2022- 11:17pm Jefferson – Federal Court of Appeal indicates that a taxpayer had not “demolished” the Minister’s assumption where it is demonstrated to be somewhat incorrect Email this Content The taxpayer relied on a statement in Hickman that the “initial onus of ‘demolishing’ the Minister’s exact assumptions is met where the appellant makes out at least a prima facie case.” ... In rejecting this position, Monaghan JA stated that the taxpayer “places far too much emphasis on the word ‘exact’ and gives insufficient weight to the word ‘demolish’ in … Hickman. ” and further stated that “establishing some consideration for the cheques is not sufficient to demolish the Minister’s assumption,” noting in this regard that the “purpose of pleading the assumption is to provide the appellant with notice of the case the appellant has to meet” and here, the taxpayer knew that, in the context of a s. 160 assessment, he needed to establish that he had provided fair market consideration for the cheques, “not merely some consideration.” ... Canada, 2022 FCA 81 under General Concepts – Onus. ...
News of Note post
10 July 2023- 11:43pm CRA indicates that an s. 104(21) designation can be made re distributing the taxable half of a trust capital gain to a corporate beneficiary – who receives no CDA addition Email this Content An inter vivos Canadian resident trust pays an amount equal to its net taxable capital gains for the year to a Canadian private corporation that is a beneficiary and designates that amount pursuant to s. 104(21). ... (a)(i.1) of the capital dividend account definition, there would be no addition to the corporation’s CDA – whereas there would be such an addition if both portions of the capital gains were distributed to the corporate beneficiary. ... Summary of 20 June 2023 STEP Roundtable, Q.12 under s. 89(1) – CDA – (a.1). ...