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G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 UK would have been required to accord foreign tax credit to dual resident company if the US had imposed its taxes in accordance with the PE article A US company (“GEFI Inc.”) and UK company (“GEFI”) in the GE group formed a Delaware LP (the “LP”) with GEFI Inc. as the 1% general partner and GEFI as the 99% limited partner, LP made five intercompany loans and also received some loans from its partners as capital contributions. ...

Cheshire Cavity Storage 1 Ltd & Anor v Commissioners for Her Majesty's Revenue and Customs, [2022] EWCA Civ 305-- summary under Regulation 1102(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Regulation 1102(2) a cavity formed out of rock to store gas was not “plant” and was premises or land The taxpayer, which was engaged in the development, construction, and operation of gas storage facilities in the UK, was found not to be entitled to capital allowances in respect of the expenditure incurred on the introduction of water into salt bearing rock so as to dissolve the rock and create an impervious cavity (“leaching”), and the displacement of the resulting brine by the introduction of gas (“de-brining”) so as to permit the storage of gas in the cavity, on the basis that the cavities were not “plant” (an undefined term). ...

Johnson & Johnson Inc., 94 DTC 6125, [1994] 1 CTC 244 (FCA)-- summary under Section 9 Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement reimbursement of an expense which never should have been paid reduces that expense rather than constituting income A federal sales tax refund was not receivable by the taxpayer until the Minister had given some public and irrevocable indication thereof. ...

Johnson & Johnson Inc., 94 DTC 6125, [1994] 1 CTC 244 (FCA)-- summary under Paragraph 12(1)(b) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) Before going on to find that a federal sales tax refund did not represent income in the taxation year in question (the 1982 taxation year) on another basis, Hugessen J.A. found that it was not receivable by the taxpayer in that year because the Minister had not yet given some public and irrevocable indication thereof. ...

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) subsequently discovered bad debts not claimable; unbilled disbursements deductible under s. 9 A review of a law firm's accounts in 2005 revealed that accounts had been rendered in 2002, 2003 and 2004 which were uncollectible and which had not been written off. ...

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Subparagraph 251(2)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(2)- Paragraph 251(2)(c)- Subparagraph 251(2)(c)(i) shareholders do not indirectly own any of the corporation’s property One-half of the shares of the 5,000 shares of the “Western Company” were owned by the “Alberta company,” and the other half were owned by the “Saskatchewan company.” ...

The Humber College Institute of Technology & Advanced Learning v. ...

Addison & Leyen Ltd., 2007 DTC 5365, 2007 SCC 33, [2007] 2 S.C.R. 793-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) delay in assessing under s. 160 not reviewable The taxation year of a corporation ("York") owned principally by one of the applicants ("Addison") ended on September 28, 1989 by virtue of a sale of York to a third party ("Senergy"). ...

R & C Commrs., [2012] EWCA Civ 927 (CA)-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance In order to shelter a capital gain which he had realized, the UK taxpayer purchased two options on the FTSE 100 index to be settled in cash: a put option (Option 1"); and a call option ("Option 2") with essentially the same strike price. ...

R & C Commrs v. Mertrux, [2012] UKUT 274 (Tax and Chancery Chamber)-- summary under Section 167.1 Summary Under Tax Topics- Excise Tax Act- Section 167.1 The taxpayer was a Mercedes dealer, licensed through Daimler-Chrysler UK ("DCUK"). ...