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4 July 2018- 7:00am 9118-5322 Québec – Tax Court of Canada indicates that transmitting purchaser new home rebate forms to CRA (or the ARQ) is imperative to the claiming by the builder of the rebate amount Email this Content Lafleur J indicated that a builder cannot deduct from net tax for the amount of new housing rebates credited to its home purchasers in a reporting period unless it submits the signed prescribed forms of the purchasers to the ARQ (or CRA, as applicable) in that month. ...

13 August 2018- 4:55am Ardmore Construction – Court of Appeal of England and Wales accepts that the determination of source of income is to be made on a multifactorial and practical basis Email this Content In Folio S5-F2-C1, CRA states that the source of interest generally is in the country of residence of the debtor. ...

14 August 2018- 11:10pm Saramac – Quebec Court of Appeal confirms the voiding of a search warrant based on failure to disclose that lawyers worked at the targeted premises Email this Content When the ARQ laid the information seeking a search warrant for a search of the taxpayers’ office, it did not disclose, despite being aware that this was likely, that a lawyer and notary worked at those premises, and the search warrant accordingly was issued by the magistrate without knowledge of this. ...

25 September 2018- 12:42am Borealis Geopower – Tax Court of Canada found that a taxpayer had “physically” received unearned government assistance Email this Content Although all the conditions for the receipt of government assistance had not yet been (and never were) satisfied, Campbell J found that the taxpayer had “physically acquired” the funds in question through depositing a cheque to a trust account of its own formation and thereafter disbursed the funds out of the account to fund its project without any practical hindrance by the government foundation in question (which appeared to have waived the condition referred to above). ...

4 October 2018- 12:06am LPIC – Tax Court of Canada finds that LPIC is not exempt under s. 149(1)(d.5) because its owner (the Law Society) merely regulates lawyers rather than governing Ontarians Email this Content Whether LPIC, which was a subsidiary of the Law Society of Upper Canada, qualified as a tax exempt, turned on whether the Law Society satisfied the condition in s. 149(1)(d.5) of being a “public body performing a function of government in Canada.” ...

16 October 2018- 8:25am Barejo – Tax Court of Canada issues a modified answer in order to accommodate an appeal to the FCA Email this Content Barejo Holdings indicated that notes held by a BVI open-ended investment fund constituted debt for purposes of the Act. ...

8 November 2018- 11:30pm Chao – Tax Court of Canada finds that a judgment issued based on a legally unsupportable concession of Crown counsel could not be varied Email this Content The taxpayer appealed the denial of employment expenses and a GST rebate. ...

22 January 2019- 11:47pm Développements Béarence – Federal Court finds that CRA cannot require a taxpayer to reformat its information for CRA’s reading convenience Email this Content Grammond J had previously made an order pursuant to s. 231.2 that the taxpayer (“Béarence,” a land developer with numerous land sales and who had been undergoing a CRA audit) provide, within five days, an Excel file containing all the daily transactions for its 2012 to 2015 years and a report of transactions by each general ledger account for those years. ...

6 February 2019- 11:47pm Lapierre – Tax Court of Canada finds that a Canadian resident working for a UN-authorized agency in Afghanistan was not exempted Email this Content A Canadian resident, who was an employee of the International Security Assistance Force (ISAF) in Afghanistan serving as an international civilian consultant, would have been exempted on his salary if the ISAF had qualified as a UN-affiliated agency or if it was a non-military body that was a subsidiary body to the NATO Council. ...

17 February 2019- 11:35pm Ark Angel Foundation – Federal Court of Appeal confirms CRA’s revocation of charitable registration for paying unsubstantiated consulting fees to a director Email this Content The Foundation, a charitable foundation, received most of its revenues from three other registered charities (including the Humane Society of Canada Foundation) that were dominated by the same individual, and disbursed most of those revenues to those three charities, except that it paid approximately 1/3 of its revenues to the individual. ...