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1 April 2025- 11:30pm MEGLobal – Tax Court of Canada effectively finds that a taxpayer had no remedy for a refusal of CRA to accept a requested s. 247(10) downward adjustment Email this Content In objections of the taxpayer to reassessments of three of its taxation years to reflect upward transfer pricing adjustments under s. 247(2), it included requested downward adjustments pursuant to s. 247(10). ...

30 April 2025- 3:19am Gross – Quebec Court of Appeal finds that a corporation’s controlling shareholder provided services, to fulfil its contractual obligations, qua employee, not independent contractor Email this Content A CPA (Mr. ...

4 May 2025- 11:17pm Delta 9 Cannabis – Alberta Court of King’s Bench determines that a reverse vesting order should not permit the target corporation to transfer out future s. 80 income tax liabilities Email this Content A cannabis producer (“Bio-Tech”) had entered CCAA proceedings. ...

26 May 2025- 10:53pm Naugle – Federal Court requires CRA to reconsider cancelling tax under s. 207.06(1) given inconsistencies in the record as to when CRA notified of the TFSA over-contribution Email this Content The taxpayer sought cancellation pursuant to s. 207.06(1) of an assessment of taxes regarding her excess contributions to her TFSA for her 2021 and 2022 taxation years. ...

4 August 2025- 11:29pm Uppal – Tax Court of Canada infers Ministerial acceptance of late HBP withdrawals because CRA only challenged them on another ground Email this Content The taxpayers, after purchasing a home in December 2020, withdrew from their RRSPs in reliance on the home buyers’ plan (HBP) rules in both 2021 and 2022. ...

3 September 2016- 9:57pm Oldcastle Building Products – Tax Court of Canada finds that compensation to a corporation's research head based on a percentage of its net sales of new products was not a “bonus” for SR&ED ITC purposes Email this Content Reg. 2900(9) provides that salary and wages for SR&ED investment tax credit purposes excludes “bonuses” and “remuneration based on profits.” ...

15 November 2016- 12:15am Blank – Australian High Court briefly affirms a finding that phantom units were not taxable when they vested Email this Content What essentially was a deferred compensation plan granted phantom units to an individual, who started off as an employee of Glencore International AG (“GI”) and later became employed by an Australian subsidiary, to participate in the cumulative profits of GI, although it was somewhat dressed up to look like he was investing in shares of the ultimate Swiss parent (Glencore Holding AG). ...

19 December 2016- 12:38am Suncor – CRA abandons attempt to impute a hedging contract between Petro-Canada and an indirect UK subsidiary Email this Content When an indirect UK subsidiary of Petro-Canada acquired another UK company with an interest in a North Sea oilfield, Petro-Canada effectively locked in the price of oil in relation to this acquisition by entering into a forward contract with Morgan Stanley and Deutsche Bank respecting a specified quantity of 28,000 barrels of oil per day for a 3.5 year period under which it would be required to make cash payments to the counterparties if the price of oil went up, and conversely if the price of oil went down. ...

10 April 2017- 11:16pm 1245989 Alberta – Tax Court of Canada finds that the use of class PUC-averaging to bump the PUC of personally-held shares was abusive under s. 245(4) Email this Content An individual (Mr. ...

24 April 2017- 12:43am Chevron Australia – Full Court of Federal Court of Australia finds that a cross-border loan made on arm’s length terms would have benefited from a parent guarantee or other security Email this Content The U.S. subsidiary (“CFC”) of an Australian company (“CAHPL”) in the Chevron multinational group borrowed in the U.S. commercial paper market at a borrowing cost of about 1.2% with the benefit of a guarantee from their ultimate U.S. parent, and on-lent U.S.$2.45 billion of such funds under an unsecured Australian-dollar credit facility to CAHPL at about a 9% interest rate. ...