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26 April 2022- 10:58pm Dow ULC – Federal Court of Appeal finds that the Tax Court cannot reverse a CRA opinion that a requested s. 247(10) downward adjustment is inappropriate Email this Content In reassessing the taxpayer under s. 247(2), the Minister did not allow a requested “downward” adjustment under s. 247(10) (to increase the interest expense on a loan from a Swiss affiliate by $3.26 million) because of a limitation period in the Canada-Switzerland Tax Treaty. ...

7 February 2023- 10:56pm Fortius – Federal Court of Appeal finds that CRA was not to be precluded from revoking registered charity status prior to the charity’s objection and appeal being heard Email this Content After a registered charity (Fortius) received a notice informing it that its registration as a charity would be revoked 30 days later, it could have followed the normal process of filing an objection and, if the Minister confirmed her decision, filing an appeal pursuant to s. 172(3) (an “application”), which would be heard on its merits. ...

18 April 2023- 10:52pm Pharma Coréalis – Court of Quebec finds that putting pharmaceutical companies’ drugs into capsules for clinical tests qualified as manufacturing for sale Email this Content Coréalis entered into “service agreements” with pharmaceutical companies pursuant to which it would develop and manufacture clinical lots of solid oral dosage forms (tablets, capsules and granules) containing an active pharmaceutical ingredient provided by the companies. ...

17 August 2023- 11:36pm Bonnybrook – Federal Court of Appeal finds no reviewable error in CRA’s decision that failure to file returns for 13 years was not justified by major health problems Email this Content For its 2003 to 2015 taxation years, Bonnybrook did not file corporate tax returns and, consequently, was not entitled to receive dividend refunds. ...

13 September 2023- 11:44pm Vefghi Holding – Tax Court of Canada disagrees with the CRA position that connected-corp. status must be tested at the (trust year-end) effective date of a s. 104(19) designation Email this Content Partway through its calendar taxation year, a family trust received a dividend from a family corporation (Consultant Inc.), paid that dividend to a corporate beneficiary (Vefghi Corp., also with a calendar year end) and in its return for that taxation year, made a s. 104(19) designation. ...

14 November 2023- 10:06pm Bank of America – Federal Court finds that it was fair and reasonable for CRA to deny relief from a mistake attributed to outsourcing all of a tax department Email this Content BANA outsourced all its Canadian tax department in 2018 to EY. ...

9 January 2024- 12:24am Brookfield Renewable Power – Court of Quebec reduces the deductible interest on loss consolidation loans from 14% to 8.75% Email this Content In connection with a September 2009 loss consolidation transaction between a “Lossco” in the Brookfield group (“BRPI”) and its “Profitco” subsidiary (“BEMI”): Two Newcos with nominal share capital were lent $2.25 billion and $0.525 billion by BRPI pursuant to unsecured demand notes bearing interest at 14%; Each Newco used the loan proceeds to subscribe for non-cumulative preferred shares of BRPI; On the same day, BEMI acquired the Newcos for a nominal amount and they were wound up into BEMI, so that BRPI held $2.275 billion of loans in its subsidiary, and BEMI held $2.275 billion of preferred shares of its parent; and The loans were left outstanding for approximately five months, then: BRPI declared and paid a dividend on the preferred shares to fund the payment of all the accrued interest on the loans, and those shares and loans were redeemed and repaid by way of set-off. ...

22 January 2024- 11:31pm Gestion Roy – Federal Court of Appeal confirms that a company’s payment of premiums on whole life policies where it was the beneficiary but not owner engaged ss. 15(1) and 246(1) Email this Content Various whole life policies on the life of a resident individual (Mr. ...

29 January 2024- 11:15pm Castro – Tax Court of Canada finds that a lender-required property transfer to a subsidiary whose shares were pledged, was non-arm’s length Email this Content As a condition to receiving a loan to fund the renovation of a property of the Castros, they were required to transfer the property to a corporation of which they were equal shareholders and to pledge the voting shares of the corporation to the lender. ...

12 February 2024- 11:40pm Total Energy – Tax Court of Canada finds that an acquisition of an insolvent public company with losses by a SIFT trust was an abuse of s. 111(5) Email this Content In September, 2007, most of the equity of an insolvent public corporation (“Biomerge”) was acquired by the company (“Nexia”) of two individuals involved in acquiring and selling loss companies, resulting in Nexia holding all of non-voting common shares of Biomerge (representing 80% of its equity) and 45% of its voting common shares. ...