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29 August 2023- 11:13pm Thomas – Federal Court allows the provision of new evidence on an application for judicial review Email this Content The taxpayer’s request for waiver of interest and penalties regarding her late filing of T1135 forms, based on the medical situation of her and her husband, was denied (at two levels) on the grounds that such situation did not prevent her from filing those forms on time. ...

2 October 2023- 11:03pm Adboss – Federal Court of Appeal confirms, based on abuse of process, the striking of the Minister’s assumption that a company’s “controlling mind and management” was in Canada Email this Content The Minister’s reply, to the taxpayers’ appeals of assessments denying zero-rating of taxable supplies made by them to a Cyprus company (“Lowfroc”) on the basis that Lowfroc was a resident of Canada, pleaded an “assumption” that “at all material times, the controlling mind and management of Lowfroc was in Canada.” ...

3 October 2023- 11:19pm Adlexco – Court of Quebec finds that the presence of any large business in a JV taints all inputs acquired by the operator for ITR recapture purposes Email this Content When Ontario (and other provinces) agreed to join the HST system, one of the added features of the provincial component of the HST system was that input tax credits (ITCs) to which "large businesses" otherwise would be entitled for various categories of purchases (such as fuel, electricity, telecommunications services, food and entertainment) were "recaptured" (i.e., effectively denied), subject to a phase-out of this rule. ...

22 November 2023- 10:57pm Horvath Estate – Alberta Court of King’s Bench declines to canvas the constitutional issue of whether ITA s. 159 is paramount over the Alberta Estate Administration Act Email this Content The personal representatives of an insolvent estate proposed to distribute its remaining assets pro rata to all the unsecured creditors as required by the terms of s. 27 of the Estate Administration Act (Alberta). ...

12 December 2023- 11:00pm Walby – Tax Court of Canada finds that s. 248(30) provided no credit for the cash component under a gifting program Email this Content MacPhee J applied Maréchaux to find that since the gifting program participated in by the taxpayers was a single interconnected arrangement with a view to profiting from large charitable receipts, none of the “gifts” made by the taxpayers including their cash contributions, qualified as gifts for s. 118.1 purposes, so that no credit could be claimed for even the cash components, as now argued by the taxpayers. ...

13 December 2023- 10:52pm Pinnacle International – Tax Court of Canada reallocates partnership profit under s. 103(1) based on relative contribution Email this Content The taxpayer and another wholly-owned subsidiary (“Taylor”) of the same corporation (“PIRG”) were the 5% and 95% partners, respectively, of a partnership, with an October 31 year end, which was engaged in developing a Vancouver condominium project. ...

. – Tax Court of Canada declines to treat a letter to CRA enclosing an SR&ED claim that CRA had lost as a de facto request for an extended period to object, and as an objection Email this Content The taxpayer, a CCPC, was found by MacPhee J to have filed its SR&ED claim for its taxation year ending on June 30, 2018 on a timely basis on December 20, 2019. ...

20 March 2024- 10:46pm Darmos Family Trust – Ontario Superior Court of Justice finds that “Alberta” family trusts whose major decisions were made in Ontario, were resident there Email this Content The assets of the two Darmos family trusts were mostly shares of corporations holding the investments derived from the sale of a company of which Mr. ...

26 March 2024- 11:10pm Sigma Chi – Federal Court of Appeal finds that a charity providing scholarships mostly to its frat members and not controlling a foreign scholarship program, breached ss. 149.1(1)(a) and (a.1) Email this Content Laskin JA found no reversible errors in the Minister’s findings that the charitable registration of the appellant (Sigma Chi), which described itself as an international fraternal organization, should be revoked: it was devoting the majority of its scholarship funds to Sigma Chi members and pledges (i.e., providing private benefits to its members through such “in-house” scholarships, contrary to s. 149.1(1)(a)); it provided funds to non-qualified donees (contrary to s. 149.1(1)(a.1)) by making loans to Sigma Chi fraternity housing corporations, established to provide housing to members; it failed (also contrary to s. 149.1(1)(a.1))to maintain direction and control over the Horizon Scholarship program, a program partially funded by Sigma Chi and administered in the United States. ...

27 March 2024- 11:19pm Animal Expert Maisonneuve – Federal Court finds that CRA could not be required to accept the taxpayer’s first return for a year after the normal reassessment period Email this Content CRA did not receive the taxpayer’s income tax return for its taxation year ending January 31, 2015 and assessed that year in June 2015 based on information in the taxpayer’s GST returns. ...