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21 April 2024- 10:19pm Persaud – Tax Court of Canada applies “the presumption of consistent application” to find that “resident” has the same meaning in s. 118(6)(b) as elsewhere Email this Content The taxpayer paid the $18,700 cost of the hospitalization and rehabilitative care of his father (Dennis), a Guyanese resident, who had a heart attack while in Canada on a visitor’s visa for a two-week stay. ...

7 May 2024- 11:42pm Litman – Tax Court of Canada finds that a laneway house built atop an unsevered garage qualified as a new residential complex for HST rebate purposes Email this Content Mr. ...

26 May 2024- 9:16pm Gillies – Tax Court of Canada had no jurisdiction regarding an employee’s complaint that CRA had not credited him for source deductions withheld but not remitted Email this Content Mr. ...

18 June 2024- 11:45pm Tourigny – Court of Quebec finds that damages for a burnt warehouse were compensation for lost profits rather than proceeds of goodwill Email this Content The taxpayer (“Trac-World”), whose warehouse was destroyed by fire, received damages from the local municipality in settlement of its claim for providing inadequate water supply during the fire. ...

16 December 2024- 11:27pm Foix – CRA reiterates that Foix overruled a more restrictive approach to s. 84(2) in some earlier cases (and restricts Geransky) Email this Content CRA provided detailed comments on Foix (where the FCA found that s. 84(2) applied to a particular hybrid sale transaction) in 10 October 2024 APFF Roundtable, Q.3. ...

16 January 2025- 12:17am Doostyar – Federal Court of Appeal indicates that judgments should not be provided to the parties in draft for non-substantive comments Email this Content The Tax Court judge sent a draft judgment (disallowing the taxpayers’ appeal) to the parties and asked for their comments on any “typographical, grammatical, punctuation, or [any] similar error[s] or any omissions” and any “comments in respect of the written presentation of…[the] decision”, but not so as to revisit the substance of the decision. ...

24 March 2025- 11:12pm Excavations Marchand – Court of Quebec finds that a construction company’s equipment used to provide concrete at a construction site qualified as for manufacturing goods for sale Email this Content A construction company contracted with Hydro-Quebec for the installation and operation of an on-site portable concrete-producing facility for the provision of the concrete in the installation of a large hydro-electric dam at a remote location. ...

27 July 2025- 11:32pm Pommet – Court of Quebec finds that a former Quebec resident spending significant time in Quebec, supervising rental properties and hunting, was an Ontario resident Email this Content The taxpayer was found to be resident in Ontario, given that he considered his farm in Ontario, which he had acquired in 2015 a number of years after separating from his Quebec wife (leaving independent adult children in Quebec), to be his home, notwithstanding that he spent around 100 to 120 days each year in Quebec to supervise his residential rental properties there and to spend time at his Quebec hunt camp, and his riverside chalet for duck hunting. ...

7 June 2015- 10:47pm Pellerin – Tax Court of Canada finds that relatedness under the 24-month QSBC test need only be tested at the disposition time Email this Content Para. ...

19 September 2016- 11:20pm Oxford Properties – Tax Court of Canada finds no abuse in bumping LPs to which the target transferred buildings pre-closing and then selling the bumped LP interests to tax exempts after 3 years Email this Content When Oxford Properties was sold to an OMERS subsidiary, the purchaser first negotiated that Oxford would drop various properties down into LPs on a s. 97(2) rollover basis, with those partnership interests subsequently being bumped under s. 88(1)(d). ...