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Decision summary
Shallhorn v. Agence du revenu du Québec, 2019 QCCQ 449 -- summary under Paragraph 118.2(2)(l.2)
Such an interpretation goes against the purpose of the Act …. ...
Decision summary
Victoria Power Networks Pty Ltd v Commissioner of Taxation, [2019] FCA 77 -- summary under Nature of Income
In finding that the Customer Cash Contributions were ordinary income to the Distributors, Moshinsky J stated (at para. 165): As the Distributors’ businesses included connecting new customers to the electricity network, and as the Customer Cash Contributions were gains (in the sense that they were amounts derived) in respect of new connections, it follows that they constituted ordinary income …. ...
Decision summary
Fono v. Agence du revenu du Québec, 2018 QCCQ 10534 -- summary under Subsection 2(1)
Before finding that the taxpayer continued to reside in Quebec for his 2009 and 2010 taxation years, Pokomàndy JCQ stated (at paras. 69-70, TaxInterpretations translation): The Court is convinced … that since 2011 this project of going to work in Ontario in order to perfect his English has become a life project that materialized with the residence transfer to this location. ...
Decision summary
A Oy v. Veronsaajien oikeudenvalvontayksikkö, [2019] EUECJ C-410/17 (10 January 2019) (European Court of Justice (9th Chamber)) -- summary under Subsection 153(1)
Similarly, in the second (dismantling) case (paras. 57, 59: [T]he value of the performance of dismantling and waste disposal … must be regarded as equal to the amount that the purchaser, that is a demolition company, takes into account as a factor reducing the purchase price of the goods to be dismantled. ...
Decision summary
Kyard Capital 2007 Inc. v. Agence du revenu du Québec, 2019 QCCQ 1617 -- summary under Subsection 15(1)
After noting that the description of the legal services provided had not been revealed to the ARQ on the grounds of privilege, Chalilfour JCQ stated (at paras. 133-135, TaxInterpretations translation): Not waiving professional privilege could certainly render the reversing of the presumption of validity of an assessment … more difficult. ...
Decision summary
Unidisc Musique Inc.v. Agence du revenu du Québec, 2019 QCCQ 1818, rev'd 2021 QCCA 393 -- summary under Class 14.1
In fact, the quality of the sound recording had everything to do with the quality of the physical medium …. ...
Decision summary
Gagnon v. Amazon.com Inc., 2019 QCCA 1166 -- summary under Subsection 261(1)
If the alleged fault of the respondents rested solely on the erroneous collection of taxes on products sold, it could be concluded that the recourse sought attempted to circumvent the ETA and STA …. ...
Decision summary
National Car Parks Ltd v Revenue and Customs, [2019] EWCA Civ 854 -- summary under Consideration
A customer pays for parking in a car park of the appellant (NCP) by going to the ticket machine which, on its tariff board, displays a price for one hour of £1.40 – but also states that change is not given but overpayments are accepted. ...
Decision summary
Agence du revenu du Québec v. Teitelbaum, 2019 QCCA 1408 -- summary under Subsection 70(3)
. … In sum, I am of the view that the debt claim bequeathed to the Taxpayer was transferred to her on November, 12, 2008, being the date of death of Mr. ...
Decision summary
Denis v. Agence du revenu du Québec, 2019 QCCQ 6708 -- summary under Subparagraph 45(1)(a)(ii)
. … [N]o transformation or modification of much significance was made to the Triplex in order for the three units to be linked in some manner to each other. ...