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Conference summary
16 June 2014 STEP Roundtable, 2014-0526591C6 - STEP CRA Roundtable June 2014 Question 9 -- summary under Subsection 156(1)
16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable June 2014 Question 9-- summary under Subsection 156(1) Summary Under Tax Topics- Income Tax Act- Section 156- Subsection 156(1) relief for interest and penalties on deficient inter vivos trust instalments Does CRA assess instalment interest and penalties where an inter vivos trust has not made instalment payments required under s. 156? ...
Decision summary
Clyde & Co LLP & Anor v Bates Van Winkelhof , [2012] EWCA Civ 1207 -- summary under Section 96
Clyde & Co LLP & Anor v Bates Van Winkelhof, [2012] EWCA Civ 1207-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 partner in partnership cannot be an employee The claimant, who was a solicitor practising as an equity member of a limited liability partnership, and who was expelled as a member, was found not to be a "worker" entitled to protection under the Employment Rights Act 2010 (UK). ...
Decision summary
Goldcorp Exchange Ltd & Ors v. Leggett & Ors, [1994] UKPC 3, [1995] 1 AC 74 -- summary under Ownership
Goldcorp Exchange Ltd & Ors v. Leggett & Ors, [1994] UKPC 3, [1995] 1 AC 74-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership no ownership of unascertained goods At the time banks appointed receivers for a dealer in precious metals, the dealer had a stock of precious metal bullion that was substantially less than that which was required to satisfy contracts of the public for purchases of precious metals for future delivery. ...
Article Summary
Allan Lanthier, "Tax relief for family business transfers: A legislative fiasco – Part I / Tax relief for family business transfers: A legislative fiasco – Part II", Canadian Accountant, 8 July 2021 (Part I) and 9 July 2021 (Part II) -- summary under Paragraph 84.1(2)(e)
Allan Lanthier, "Tax relief for family business transfers: A legislative fiasco – Part I / Tax relief for family business transfers: A legislative fiasco – Part II", Canadian Accountant, 8 July 2021 (Part I) and 9 July 2021 (Part II)-- summary under Paragraph 84.1(2)(e) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) Overview Bill C-208 generally provides that an individual selling qualified small business shares or shares of a family farm or fishing corporation to a corporation controlled by the individual’s children or grandchildren who are at least 18 years of age will benefit from capital gains treatment rather than a s. 84.1 deemed dividend provided that such purchaser does not dispose of those shares for at least 60 months. ... Example of strip Emily transfers her shares of a small business corporation (Petco) with nominal tax basis and paid-up capital to a Newco- in which her daughter owns nominal value special voting shares giving her voting control, and Emily owns the balance of the equity – in consideration for a promissory note, which is repaid over the next five years with intercorporate dividends received by Newco from Petco. ... Furthermore, the math in the formula is wrong – even if it were effective, it would only eliminate the deduction at taxable capital levels of $510 million, not $15 million. ...
Decision summary
Racal Group Services Ltd. v. Ashmore & Ors., [1995] BTC 406 (CA) -- summary under Rectification & Rescission
Ashmore & Ors., [1995] BTC 406 (CA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission intended terms not clear A deed for payment of £70,000 to charity, although it was intended to comply with an income tax requirement that the payment be for a period which might exceed three years, was executed in terms that ensured that the period would not exceed three years. ...
Conference summary
27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6 - TOSI – Excluded Shares & Related Business -- summary under Excluded Shares
27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business-- summary under Excluded Shares Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares exclusion for investment business or passive amounts not derived from a related business 29 May 2018 STEP Roundtable Q.7, 2018-0744031C6 indicated that the shares of a corporation that did not generate business income (e.g., a corporation that generated rents that, given the level of activity, constituted income from property) cannot qualify as excluded shares, whereas in Examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults (December 13, 2017), shares of a corporation earning income from passive investment assets qualified as excluded shares. ...
Decision summary
Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794 -- summary under Agency
Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794-- summary under Agency Summary Under Tax Topics- General Concepts- Agency a placement service providing non-employee temps to clients was not paying the temps’ compensation on the clients’ behalf An employment bureau (Adecco) introduced temporary staff ("temps"), who were not Adecco employees, to clients looking for a temporary worker to undertake an assignment, and if the temps accepted an assignment, Adecco paid them for the work they did for the clients – and collected those amounts plus a mark-up from the clients. ...
Decision summary
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber) -- summary under Subsection 104(13)
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) The son of the taxpayer, who was the beneficiary of his own life insurance policy, likely died in 1998 when he was abducted by Angolan rebels, but this was never conclusively established. ...
Technical Interpretation - Internal summary
10 June 2019 Internal T.I. 2019-0796221I7 F - Qualification d’un véhicule à titre de « voiture de tourisme » -- summary under Paragraph 13(7)(b)
10 June 2019 Internal T.I. 2019-0796221I7 F- Qualification d’un véhicule à titre de « voiture de tourisme »-- summary under Paragraph 13(7)(b) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(b) s. 13(7)(b) applies when passenger vehicle converted to taxi use A "passenger vehicle” initially acquired for personal use and subsequently converted to taxi use will at that time be considered by virtue of s. 13(7)(b) to have been “acquired primarily for use as a taxi,” so that such quoted exclusion from the s. 248(1) definition of “passenger vehicle” would thereafter apply. ...
Decision summary
Halsall & Ors v Champion Consulting Ltd & Ors, [2017] EWHC 1079 (QBD) -- summary under Negligence, Fiduciary Duty and Fault
Halsall & Ors v Champion Consulting Ltd & Ors, [2017] EWHC 1079 (QBD)-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault knowledge that advice – that investing in a tax shelter was a “no brainer”- was negligent, accrued when HMRC started investigating The claimants, who were non-tax solicitors, claimed that they had been negligently induced by the defendant accounting firm (“Champion LLP”) and an associated corporation (“Champion Consulting”) to invest in two tax schemes referred to as the "charity shell" and "Scion" film schemes. ... The fact that some of the companies succeeded and that some of the schemes went unchallenged by the Revenue is in my view irrelevant to the question of whether the reasonably competent tax adviser would have given an unconditional assurance that the charity shell scheme would work effectively. … [T]he failure … lay in not explaining that the valuation was pivotal to the success of the scheme and how this wide range of companies could all be valued at four times the initial subscription and this failure amounted to a breach of duty. ... With respect to the Scion film schemes, Moulder J found (at paras. 318, 319 and 335): … [I]t seems to me that the defendant did not advise that the claimant could lose more than their initial contribution. … The evidence is clear that the defendants did not point out the risk of the additional liability arising out of the outstanding loan and exposure to a tax charge in the event of the loan being written off. … [I]n my view the advice of Ms Molloy [an accountant and chartered tax advisor] that the prospects of success of the film scheme were 75% was outside the range open to her and amounted to a breach of duty being advice such as no reasonably well-informed and competent member of that profession could have given. ...