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Decision summary
Hudson’s Bay Company v. OMERS Realty Corporation , 2016 ONCA 113 -- summary under Clause 149(1)(o.2)(iii)(B)
In the case of a lease, there can be no assignment of the lease to the limited partnership – it must be assigned to the general partner. ...
Decision summary
Commissioner of Taxation v PricewaterhouseCoopers , [2022] FCA 278 -- summary under Solicitor-Client Privilege
. … It is therefore necessary to consider, on a document-by-document basis, whether each Sample Document is subject to legal professional privilege. ...
Decision summary
CS Communication v. Agence du revenu du Québec, 2022 QCCQ 1175 -- summary under Paragraph (a)
Agence du revenu du Québec, 2022 QCCQ 1175-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Contract Payment- Paragraph (a) expenditures under an agreement to develop software for a 3rd party pursuant to its specifications were not associated with contract payments The taxpayer (“CS Canada”), which carried on a business of developing software for use in the aeronautics industry, entered into a “long term purchase agreement” with a third party (“Pratt & Whitney” or “P&W”) for the sale to it of control system software. ...
Decision summary
Boliden Mineral AB v. FQM Kevitsa Sweden Holdings AB, 2023 ONCA 105 -- summary under Tax Indemnity
The Court found that the application judge- who had noted the contrast between the above representation, and other representations and warranties in the SPA which were limited to the knowledge of the sellers – had reasonably concluded that such representation could be untrue as of the time of closing even if the prospect of reassessment was not reasonably expected by FQM. ...
Decision summary
Gaudreau v. The King, 2023 TCC 115 -- summary under Solicitor-Client Privilege
Before finding that the memo was potentially relevant and should be produced, St-Hillaire J noted that there was no accountant-client privilege, stating (at para. 59, TaxInterpretations translation): According to the appellant, if such advice were to be systematically disclosed, the quality of communication between accountants and their clients, and compliance with the Act would be reduced …. ...
Decision summary
Gestion M.-A. Roy Inc. v. Canada, 2024 FCA 16 -- summary under Subsection 15(1)
Gestion Roy was the owner of such policies (entitling it to the cash surrender value of the policies at any time), so that it was “enriched” when the premiums were paid by R3D (with Boivin JA stating in this regard, at para. 6, TaxInterpretations translation, that “the appellants received an advantage in that for years they owned policies with a total death benefit of $20,000,000 and all the rights attached to them, without having to pay premiums”) – and it was irrelevant to this point that, in fact, Gestion Roy never received any distribution on its policies. ...
Decision summary
Commissioners for His Majesty's Revenue and Customs v Arrbab, [2024] EWCA Civ 16 -- summary under Regulations/Statutory Delegation
. … The facts of Mr Arrbab's case are an unfortunate illustration of the reality that only a right of recourse to an independent tribunal may provide effective protection against failures of administration, including a failure to recognise that time ought to be extended. ...
Decision summary
British Columbia v. Peakhill Capital Inc., 2024 BCCA 246 -- summary under Section 243
An RVO advances the same goals as an AVO — albeit by employing a different transaction structure. ...
Decision summary
Corporation immobilière des Laurentides Inc. v. Agence du revenu du Québec, 2024 QCCQ 5297 -- summary under Effective Date
. … Thus, the return of the unit in each case was to reflect that the original taxable supply was nullified, rather than representing a further taxable supply, so that the application of the s. 332 equivalent was confirmed. ...
Decision summary
British Columbia v. 1184369 B.C. Ltd., 2024 BCCA 380 -- summary under Onus
In allowing the Crown’s appeal, Skolrood JA referred to his statement in GFL (at para. 60): I endorse the principle … in Preston that tax assumptions containing statements of mixed fact and law will not be invalidated simply on that basis if the factual underpinnings are clearly stated, there is no dispute about the legal principles and no prejudice results. ...