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8 March 2021- 10:35pm 632738 Alberta – Federal Court of Appeal finds that the determination of the scope of an ambiguously-worded waiver should be made at trial, not under Rule 58 Email this Content CRA presented the taxpayer with a form of waiver that adequately referenced the issue as being how much partnership income was to be allocated to the taxpayer. ...

16 March 2021- 11:25pm 4053893 Canada – Federal Court finds that a disclosure by a company was reasonably treated by CRA as not voluntary given enforcement action against its sole shareholder Email this Content An individual was contacted by CRA by letter and in a phone call about his failure to file returns for 10 years, his company (which also had not filed returns for 20 years) then made a voluntary disclosure (VDP) application, following which the individual filed his delinquent returns. ...

7 June 2021- 11:05pm Des Groseillers – Quebec Court of Appeal decision indicates that s. 69(1)(b) deems FMV proceeds for an employee stock option gift for s. 7 purposes Email this Content An individual who donated some of his employee stock options on the shares of a public company to arm's length registered charities, claimed the $3M fair market value of the donated options for charitable tax credit purposes, but did not include any portion of the donated options in his income under the equivalent of ITA s. 7(1)(b). ...

30 June 2021- 5:03am Cristofaro – Quebec Court of Appeal applies Oceanspan to find that a non-resident with no sources of income in Quebec could not transfer a tax credit to a Quebec taxpayer Email this Content In 2003-0026827, CRA applied Oceanspan to find that a non-resident student who has no Canadian sources of income is precluded from transferring her unutilized tuition credits to her resident father under ITA s. 118.9 because: an individual who is not resident in Canada and who has no Canadian source income would not be entitled to the tuition and education tax credits. ...

19 July 2021- 11:24pm Boguski – Federal Court of Appeal confirms rejection of attempt by CRA to use the expanded s. 174 application procedure Email this Content In 2013, s. 174 was expanded so that it could be used to request a determination by the Tax Court on questions involving a large group of unrelated taxpayers who entered into similar transactions with a third party. ...

12 August 2021- 10:28pm Pavages Vaudreuil – Court of Quebec finds that an operation of washing, sorting and crushing aggregate was separate from a road construction operation Email this Content In addition to being involved in construction (maintenance of roads, streets and bridges), the taxpayer owned several natural gravel quarries and sand pits and processed sand, river gravel, crushed stone and earth for sale to third parties and for use in its construction operations. ...

31 August 2021- 11:16pm Paletta Estate – Tax Court of Canada states that there is no “buy Canadian" requirement regarding use of expert witnesses Email this Content The taxpayer was substantially successful in its appeals for eight taxation years of denials of around $49 million in net losses from “straddle trading.” ...

3 January 2022- 10:50pm Christen – Federal Court finds that a voluntary disclosure planned before, but made after, the audit notification could be considered non-voluntary- but annuls the CRA rejection anyway Email this Content In May 2015, the plaintiff authorized her law firm to represent her in making a voluntary disclosure of her Swiss assets, and in the summer and fall of 2015, various documents were collected and organized to this end. ...

18 January 2022- 10:36pm Charron – Court of Quebec finds that all the expenses incurred in relation to a rental home under construction from the building permit to being livable were to be capitalized Email this Content The taxpayers purchased a lot, constructed a house, leased it out for a year and then sold it at a gain. ...

3 February 2022- 10:53pm Cliff – Federal Court of Appeal states that a director can resign by email or text Email this Content ITA s. 227.1(4) and ETA s. 323(5) indicate that a director cannot be assessed for unremitted corporate source deductions or GST more than two years after she ceased to be a director. ...