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17 January 2019- 11:30pm 4053893 Canada – Federal Court finds that CRA could not deny VDP relief to a corporation without explaining how its shareholder audit would have exposed the corporation Email this Content After Mr. ...

28 January 2019- 11:43pm Jencal Holdings – Tax Court of Canada finds that one of the main reasons for the existence of a holdco for one of five children was SBD multiplication Email this Content A reorganization was implemented so that a family company (“KT Holdings”) that indirectly carried on a tire business became held equally by holdcos for each of the five children. ...

5 February 2019- 11:47pm Monsell – Tax Court of Canada finds that CRA had the onus of substantiating assessments underlying s. 160 assessments where it had superior records access Email this Content The taxpayers (a husband and wife) received payments from a corporation that had been reassessed for its 2005 to 2007 taxation years and had not objected thereto. ...

11 February 2019- 11:59pm Montecristo Jewellers – Tax Court of Canada finds that export sales were not zero-rated Email this Content ETA Sched VI, Pt. ...

18 February 2019- 11:34pm Sutlej Foods – Tax Court of Canada finds that corporations but not individuals potentially can be represented in a general procedure case by their accountant Email this Content In Masa Sushi, Graham J found that a corporation could not appear “in person” in a General Procedure matter and had to appear through counsel, so that a Rule purporting to permit a corporation to appear in person with the Court’s consent would be ultra vires. ...

25 February 2019- 12:12am Fono – Court of Quebec finds that a taxpayer gradually shifting his ties to Ottawa continued to reside in Quebec while he had secondary and personal ties there Email this Content A Quebec taxpayer, who got a job in Ottawa in 2007 along with an apartment there, was found to have continued to be resident in Quebec for his 2009 and 2010 years given that he maintained significant ties with Quebec including a significant other who stayed in Quebec and gave birth there to a child in 2010 and with the taxpayer visiting Quebec on a weekly basis. ...

5 March 2019- 12:22am Zdzieblowska – Tax Court of Canada finds that CRA is required to grant an unclaimed and available new rental housing rebate when assessing to deny a new home rebate Email this Content ETA s. 296(2.1), generally requires CRA to take unclaimed rebates into account when assessing a taxpayer. ...

12 March 2019- 12:11am Revera Long Term Care – Federal Court requires CRA to reconsider whether a taxpayer’s negligence in over-reporting income in a statute–barred year permits CRA to reassess that year Email this Content The taxpayer discovered that it had overreported its income for ITA purposes by $9 million per year for years that were before the normal reassessment period. ...

27 March 2019- 11:33pm Villa Ste-Rose – Tax Court of Canada finds that interest and penalties on a late-filed GST return should be computed after netting rebate claims against the gross GST payable Email this Content A company that was not registered for GST purposes was required to self-assess itself under ETA s. 191(3) for GST on the fair market value of an assisted-living facility constructed on its behalf. ...

28 March 2019- 7:14pm Plains Midstream – Federal Court of Appeal finds that s. 16(1) can only apply to a debtor if it equally applies to the creditor Email this Content As part of a complex set of transactions, a predecessor of the taxpayer agreed to assume a $225M loan that was due in perhaps 43-years’ time and that was non-interest-bearing (except in the remote event of oil production from the Beaufort Sea) in consideration inter alia for the payment to it of $17.5 million by the debtor. ...