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News of Note post
3 September 2018- 11:44pm Custeau Court of Quebec finds that GAAR did not apply where individuals used PUC thrust upon them by an arm’s length investor (through PUC averaging) to subsequently strip surplus Email this Content When the taxpayers’ corporation (“Opco”), a small business corporation, was in financial difficulty, a Quebec regional development fund agreed to inject equity capital in Opco on terms dictated by the fund which entailed the fund investing in the common shares of Opco, so that the paid-up capital of the taxpayers’ shares was boosted from a nominal amount to $1.45 million. ...
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13 September 2018- 11:11pm BMO Tax Court of Canada finds that former s. 39(2) extended to (and carved out) FX gains on s. 39(1) dispositions Email this Content BMO used a tower structure for a U.S.$1.4 billion financing of its U.S. subsidiaries in which a subsidiary Nevada LP of BMO applied third-party borrowings made by it (or by BMO and contributed to the LP) to subscribe for common shares of an NSULC subsidiary, which acquired shares in an LLC, which lent the U.S.$1.4 billion to the U.S. subsidiaries. ... S. 39(2) went on to deem the capital gains and losses thereunder to be from the disposition of foreign currency which presumably was motivated by a concern that they otherwise would be considered to have the character of any property that was actually disposed of. ...
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28 September 2018- 2:14am Cameco Tax Court of Canada finds that having Swiss/Lux subsidiaries enter into long-term purchase contracts at a somewhat fixed price with third parties and the taxpayer did not engage s. 247(2) Email this Content Cameco Canada formed a Swiss subsidiary (“CESA/CEL,”- more precisely, a two-employee Swiss branch of a Luxembourg subsidiary ("CESA"), that was succeeded a few years later by a Swiss subsidiary ("CEL")), that entered into long-term contracts (guaranteed by Cameco Canada) for the purchase of Russian-sourced uranium from a third party (e.g., "Tenex"). ... The decision of Cameco Canada to offshore the contracts to CESA/CEL was consistent with “the purpose of the foreign affiliate regime to allow Canadian multinationals to compete in international markets through foreign subsidiaries without attracting Canadian income tax.” ...
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16 March 2020- 11:51pm BHP Billiton High Court of Australia finds that one company is influenced by the other under a stapled structure where both companies are contractually bound to act in concert Email this Content BHP Billiton Limited ("Ltd"), an Australian corporation, was part of a dual-listed company arrangement (the “DLC Arrangement") with BHP Billiton Plc ("Plc"). ... The Court stated: [T]he fact that Ltd and Plc operated in this way pursuant to a contract does not preclude a finding that they "sufficiently influenced" each other otherwise, any company would be able to place itself outside the reach of the statute (of being "sufficiently influenced" by another company) by forming a contract to govern their relationship. ...
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6 May 2020- 12:33am BMO Federal Court of Appeal finds that former s. 39(2) extended to FX gains on s. 39(1) dispositions Email this Content On unwinding a tower structure, a Nevada subsidiary LP of BMO realized FX gains on repaying U.S. ... As a technical matter, s. 112(3.1) did not apply to deny any portion of this capital loss because the NSULC paid all its dividends on a separate class of preferred shares that it had issued as a stock dividend rather than on the common shares on which the LP had realized the loss. ...
News of Note post
7 July 2020- 11:41pm Iberville Developments Federal Court of Appeal confirms that the starting ACB of a partnership interest was determined exclusively under s. 97(2)(b) Email this Content A corporate taxpayer having shopping centres with a cost amount and fair market value of $14M and $130M, respectively, contributes the properties under s. 97(2) to a newly-formed LP in consideration for boot of $14M and units with a FMV of $116M. ... After noting that such a double increase would represent “an absurd result,” Noël CJ stated: [T]he appellant’s partnership interest had already been acquired when the shopping centres were transferred, thereby eliminating any possibility that, in addition to the subsection 97(2) adjustment, the partnership interest could be increased under section 54 by the “cost”, i.e. the fair market value, of the transferred property …. ...
News of Note post
22 November 2020- 11:03pm Lockwood Financial Tax Court of Canada finds that shares received on a deferred basis from a successor of a client were fee income in the year of entitlement to receive Email this Content A broker (Lockwood) whose business included brokering deals for junior resource companies earned an up-front fee for brokering a farm-in deal for a client (LEO) in 2010. ... The Queen, 2020 TCC 128 under s. 12(1)(b) and s. 54 ACB. ...
News of Note post
23 November 2020- 11:02pm Rémillard Federal Court finds that the certified Federal Court record is open to the public absent a specific confidentiality order Email this Content The taxpayer, a retired businessman living in Barbados, sought to challenge, through judicial review, information requests made by CRA (who was reviewing his residency status) to other countries’ tax authorities. ... The open court principle allows any person to inspect a court record and any annex "that is available to the public" …. ...
News of Note post
10 February 2021- 11:07pm Landbouwbedrijf Backx Tax Court of Canada finds that Dutch legal expert testimony was required in order to establish dual corporate residency Email this Content When a Netherlands couple immigrated to Canada in 1998 to acquire a dairy farm here, they created a structure under which the farm was held in a partnership which was held by them directly as to 51% and as to 49% through a Netherlands holding company (“B.V.”) of which the wife’s sister (a Netherlands resident) was the sole director. ... The Queen, 2021 TCC 2 under s. 128.1(1)(c), Treaties Income Tax Conventions- Art. 4 and General Concepts- Estoppel. ...
News of Note post
. Tax Court of Canada finds that orthodontic practices make two supplies of services and devices Email this Content A professional corporation’s orthodontics practice claimed input tax credits on the basis of an administrative arrangement of CRA with the Canadian Dental Association under which orthodontists filed their GST returns using 35% of the patient’s total treatment cost as an estimate of the consideration for the supply of the orthodontic appliance (which was zero-rated), with only the balance treated as exempt- and with a requirement, when the annual results became available at year end, to reconcile their 35% ITC estimate with their actual taxable supplies. ... Accordingly, CRA disallowed the corporation’s input tax credit claims effectively on the basis that there was a single supply of exempt orthodontic services. ...

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