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.)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The Minister assessed the applicant, a mutual fund manager, on the basis that a payment to it by mutual funds of deferred sale charges received by the mutual funds from redeeming investors represented consideration for taxable supplies of services made by the applicant to the mutual funds. ...

Bramco Holdings Co. (1995), 21 OR (3d) 739 (CA), aff'g (1994), 17 OR (3d) 571 (Gen Div)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rewriting fiscal history Ontario farm lands were transferred to a non-resident corporation for the purpose of utilizing losses of that corporation. ...

., 2012 DTC 5052 [at at 6814], 2012 ONSC 549-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission declaration re character of Ponzi amounts received The applicants and the respondents (which were corporations held by the applicants) were defrauded in a Ponzi scheme. ...

Slipacoff, 2010 ONSC 2693-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission two-year limitations period The defendant and plaintiff held shares in an incorporated dental practice. ...

Minister of Finance, 2008 CanLII 15226 (Ont SCJ), briefly aff'd 2009 ONCA 715-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission A transfer of tangible personal property by an Ontario corporation ("1006") to a second corporation ("QL") would have been exempt from Ontario retail sales tax if QL were a wholly-owned subsidiary of 1006 at the time of the transfer. ...

The Queen, 2011 DTC 1117 [at at 628], 2011 TCC 148, aff'd 2012 DTC 5138 [at 7292], 2012 FCA 214 supra-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no implied set-off The taxpayer acquired a 100% undivided interest in a property (the "Quarter Claim") adjoining its "Golden Giant" mine subject to a 50% net profits royalty in favour of the vendor ("Teck/Corona"). ...

Commissioners for HM Revenue and Customs, [2013] UKSC 26, [2013] WLR (D) 172-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission mistake re tax consequences justified rescinding settlement of trust The claimant had settled the moneys received as damages for injury to her husband on a discretionary trust of which she and others were trustees. ...

., 97 DTC 5252, [1997] 2 CTC 286 (FCA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission retroactive effect of nunc pro tunc rectification order The taxpayers neglected to have shares that purportedly were issued to them in 1985 added to the authorized capital of the issuing corporation. ...

A.G. of Canada, 2015 ONSC 6245-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission reorganization of corporate structure to reflect what it was thought to be at the time of making a tax election The Telus group had a tiered partnership structure. ...

Re Razzaq Holdings Ltd (2000), 11 BLR (3d) 157, 2000 BCSC 1829-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission In 1992 the two shareholders of a corporation purported to transfer a total of 100 Class A shares and 100 Class B shares equally to two holding companies. ...