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Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) limited scope of PUC provisions reflected a policy choice The taxpayer ("Products"), which was a corporation resident in the U.S., transferred the shares of its subsidiary ("CAHL"), which was non-resident in Canada notwithstanding that it had been incorporated in Canada in 1929, to a newly incorporated Canadian-subsidiary of Products ("Holdings") in consideration for a common share of Holdings that had a paid-up capital equal to the fair market value of CAHL. ...

Wood & Anor v Inspector of Taxes Rev 1, [2006] EWCA Civ 26, 78 TC 1-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) taking advice from an outsider does not establish that the board was not exercising CMC At issue was whether a Netherlands corporation ("Eulalia") was resident in the United Kingdom. ...

Lockyer & Anor (for Pawson Estate), [2013] UKUT 050 (Tax and Chancery Chamber)-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business actively-manged holiday property an investment The deceased taxpayer and her three children held equal interests in a bungalow ("Fairhaven"), which they rented out as a holiday property. ...

Lockyer & Anor (for Pawson Estate), [2013] UKUT 050 (Tax and Chancery Chamber)-- summary under Investment Business Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Investment Business actively-managed rental property an investment business The deceased taxpayer and her three children held equal interests in a bungalow ("Fairhaven"), which they rented out as a holiday property. ...

R & S Industries Inc. v. Canada (National Revenue), 2016 FC 275-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) drop-down agreement interpreted as preventing a re-allocation of boot to avoid gain A transfer agreement for the drop-down under s. 97(2) of assets by the taxpayer (R&S) to a controlled LP specified that the elected amounts in a joint s. 97(2) election, and the respective portions of the Purchase Price allocated to the transferred assets, would be the minimum agreed amounts permitted under the Act, “provided …that in respect of the Goodwill, the elected amount shall, unless otherwise agreed be equal to $2,502,600.” ...

Acornwood LLP & Ors v. Revenue and Customs Commissioners, [2016] BTC 517, [2016] UKUT 0361 (Tax and Chancery Chamber)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose regard had to the actual use of the taxpayer's expenditure by the expenditure’s recipient where so directed by taxpayer In the appeal before him by five limited liability partnerships (the “LLPs”) respecting the disallowance of expenditures as trading losses, Nugee J indicated (at para. 6) that he was content to proceed on the basis of a simple example provided by the LLPs’ counsel using the figure of 100 to represent sums contributed to an LLP by individual members. ...

Leekes Ltd v HM Revenue & Customs, [2018] EWCA Civ 1185-- summary under Subparagraph 111(5)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a)- Subparagraph 111(5)(a)(ii) ability of successor to apply predecessor losses to income from same trade did not extend to profits from an enlarged trade The taxpayer (Leekes) carried on a trade of running department stores (three in Wales and one in Wiltshire) and acquired for nominal consideration all the shares of another company (Coles) that carried on a similar trade from three furniture stores and a distribution centre in the West Midlands. ...

Shanda Games Ltd v Maso Capital Investments Ltd & Ors (Cayman Islands), [2020] UKPC 2-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares minority discount to minority bloc of public-company shares The respondent (Shanda) was an exempted limited company incorporated in the Cayman Islands whose American Depository Shares (“ADSs”) were listed on the NASDAQ. ...

Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit whether an activity qualifies as “carried on with a view to profit" turns on the taxpayer’s subjective intention Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade, profession, vocation or occupation, manufacture or undertaking, or any other income earning activity, carried on with a view to profit. ...

Deloitte & Touche, LLP, 2014 DTC 5082 [at at 7068], 2014 BCSC 1083-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault tax contingency fee to auditors did not engage conflict of interest; internal memo not relevant to actual advice The defendant ("D&T"), which was the auditor of the plaintiff (Taiga), recommended that Taiga adopt a plan to minimize provincial taxes, relying on a "loop hole" in the Corporations Tax Act (Ontario), which permitted interest paid to an affiliate incorporaated outside Canada but which was resident in Canada to be received by it free of Ontario corporate tax. ...