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30 January 2018- 12:32am Referred Realty – Federal Court sets aside a CRA decision not to apply a credit under s. 221.2 based on the taxpayer’s slowness in filing returns Email this Content The taxpayer had very substantial difficulties (relating to two successive incompetent bookkeepers) in getting its records into accurate shape, that resulted in a four-year delay in filing any income tax returns although, in the meantime, it kept remitting estimates of its tax. ...

19 February 2018- 9:17pm Viterra – Tax Court of Canada finds that consequential ETA reassessments are subject to essentially the same limitations as under the ITA Email this Content CRA reassessed a company well beyond the normal reassessment period in order to allow input tax credits, which it previously had denied within the normal reassessment period (being GST on fees charged by the investment manager for employee pension plans), but made an offsetting addition of GST to the reassessment on the basis that the company was resupplying the investment management services to the pension plans and had failed to charge GST on the fees therefor imputed by CRA. ...

23 February 2018- 12:56am bcIMC – B.C. Court of Appeal indicates that enforcement of a reciprocal taxation agreement was possible pursuant to the Federal Court Act Email this Content bcIMC is a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. ...

9 March 2018- 12:54am CRA finds that an estate gift of sales proceeds of s. 70(5) property can be carried back to the terminal return – and s. 38(a.1)(ii) zeroes post-death appreciation on estate-donated shares Email this Content S. 118.1(5.1)(b) applies to most gifts made by a graduated rate estate of property that was acquired by it on and as a consequence of the deceased’s death “or is property that was substituted for that property.” ...

23 March 2018- 1:34am ONEnergy – Federal Court of Appeal finds that litigation services to recover fraudulent bonuses following a business’ termination were acquired in connection with that business Email this Content A company (“Look”) sold all the assets of its business and then successfully sued its executives for having paid themselves inflated bonuses and option termination payments out of the sales proceeds. ...

25 March 2018- 11:18pm Giguère – Court of Quebec finds that interest demanded by a receiver on a fraudulent advance did not qualify as a disposition expense on the property sold to repay the advance Email this Content The wife of the manager of a corporation received fraudulent advances from the corporation, which she used to purchase two buildings. ...

27 March 2018- 1:08am Chad – Federal Court refuses to take CRA’s word for it that it needed to redact materials in order to conceal its audit methodology Email this Content Federal Court Rule 317 provides that “A party may request material relevant to an application that is in the possession of a tribunal [e.g., CRA] whose order is the subject of the application….” ...

13 April 2018- 12:38am Rennie Produce – Full Federal Court of Australia finds that third-party documents obtained in commercial judicial proceedings were producible under a requirement issued by the tax authority Email this Content The obligation in Harman v Secretary of State for Home Department [1983] 1 AC 280 has been described as follows: Where one party to litigation is compelled, either by reason of a rule of court, or by reason of a specific order of the court, or otherwise, to disclose documents or information, the party obtaining the disclosure cannot, without the leave of the court, use it for any purpose other than that for which it was given unless it is received into evidence. ...

7 May 2018- 12:12am Haifa Trust – Court of Quebec finds that a trust with an inactive Alberta trustee whose director could be replaced at will by the Quebec patriarch was resident in Quebec Email this Content A purported Alberta-resident trust for the family of Mr. ...

14 May 2018- 12:07am Smith – Tax Court of Canada finds that two individuals jointly controlling a company were acting in concert respecting the payment of dividends so as to engage s. 160 Email this Content Two individuals held their 50-50 Opco through a holding company held by a family trust, in the case of Mr Smith, and through a family trust in the case of Mr Scott. ...