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10 July 2017- 12:17am News Australia – Federal Court of Australia finds that interest was “derived” on an accrual basis on a loan where it was a business asset and there was no collection uncertainty Email this Content Australia, whose statute still has a general inclusion of income “derived directly or indirectly from [a] source…during the income year,” has provided some of the jurisprudence on the meaning of “derived.” ...

11 July 2017- 12:57am Binder Capital – Federal Court finds that it lacks the jurisdiction to overturn CRA’s decision not to extend s. 129(1) refund-claim deadline Email this Content In 1057513, Webb JA found that a corporation was ineligible for dividend refunds for various years because it did not file the returns claiming the dividend refunds within three years of the taxation year-ends in question as required under s. 129(1). ...

12 July 2017- 12:59am Diktakis – Tax Court of Canada finds that a taxpayer and her two years old half-sister were related Email this Content ITA s. 251(6)(a) indicates that siblings are related. ...

17 July 2017- 11:56pm Pietrovito – Tax Court of Canada refuses to permit a taxpayer to correct a clear error in appealing only one of the two taxation years in dispute Email this Content Due to a clerical error by a liaison between the taxpayer and his counsel, counsel was only instructed to prepare a Notice of Appeal for Year 1 and not Year 2, notwithstanding that it was the obvious intention of the taxpayer to appeal both. ...

18 July 2017- 11:06pm Mullings – Tax Court of Canada finds that time spent administering special “medical formula” foods to a child counted as therapy administration and not as dietary control Email this Content The taxpayer’s ability to claim the disability tax credit in respect of her young child, who suffered from an inability to digest a common amino acid (“Phe”), turned on whether she was spending at least 14 hours per week on therapy, which was defined in s. 118.3(1.1)(d) to exclude “time spent on dietary…restrictions or regimes.” ...

17 August 2017- 8:23am Burlington Resources Finance – Tax Court of Canada states that taking discovery questions “under advisement” should stop Email this Content CRA disallowed, in full, under s. 247(2)(a), the deduction by Burlington of guarantee fees paid to its U.S. parent. ...

15 September 2017- 1:13am Chiang – Tax Court of Canada finds that a “reasonable error of fact” (e.g., confusion as to how to claim a deduction) established a due diligence defence to penalties Email this Content The taxpayer (Chiang) overcontributed to his RRSP (thereby incurring Part X.1 tax) because he “genuinely and reasonably believed” that he had deducted his contributions for two years in his returns for those years (but, in fact, did not enter the amounts in the deduction line) and that for a third year he had unused RRSP deduction room (which he did not). ...

9 October 2017- 12:11am Shenanigans Media – Tax Court of Canada finds that expenditures on actor’s clothing used in promotions were not deductible Email this Content The expenses of a teenage actor, who “had to maintain a certain image,” for clothing that was available for him to wear to auditions and promotional appearances, were not deductible by him or his company, given that the evidence “showed ordinary clothes that might well be worn by anyone of Mr. ...

12 December 2017- 11:15pm Masa Sushi – Tax Court of Canada finds that a corporation can only be represented in a General Procedure action by counsel (no CPAs or officers) Email this Content Rule 30(2) of the Tax Court of Canada Rules (General Procedure) provides that: Where a party to a proceeding is not an individual, that party shall be represented by counsel except with leave of the Court and on any conditions that it may determine. ...

20 December 2017- 1:51am Farm Credit Canada – Federal Court of Appeal finds that “loan corporation” for GST/HST purposes has a broader meaning than its provincial regulatory meaning Email this Content Different types of selected listed financial institutions (SLFIs) are subject to different attribution rules for determining the blended HST rate of tax to which they are ultimately subject. ...