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Decision summary

Taiga Building Products Ltd. v. Deloitte & Touche, LLP, 2014 DTC 5082 [at at 7068], 2014 BCSC 1083 -- summary under Negligence, Fiduciary Duty and Fault

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. ...
Decision summary

London & Thames Haven Oil Wharves, Ltd. v. Attwooll (1966), 43 TC 491 (CA) -- summary under Compensation Payments

London & Thames Haven Oil Wharves, Ltd. v. Attwooll (1966), 43 TC 491 (CA)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer, which operated an oil storage installation that was supplied by tankers, suffered damage to a jetty through the negligent handling of a tanker by a third party. ...
Decision summary

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 5

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 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 somewhat isolated (albeit in large amounts) loan activity in US did not represent a business under UK concepts and therefore did not entail a US PE under the UK-US Treaty A US company (“GEFI Inc.”) and UK company (“GEFI”) in the GE group formed a Delaware LP (“LP”) with GEFI Inc. as the 1% general partner and GEFI as the 99% limited partner. ...
TCC (summary)

D & D Livestock Ltd. v. The Queen, 2013 DTC 1251 [at at 1412], 2013 TCC 318 -- summary under Subsection 55(2)

D & D Livestock Ltd. v. The Queen, 2013 DTC 1251 [at at 1412], 2013 TCC 318-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) stock dividend by dividend payer did not reduce the safe income attributable to its subsidiary After a preliminary reorganization, all of the shares of the taxpayer (consisting of Class A common shares and Class D preference shares) were owned by another Canadian corporation ("HLL"), whose safe income on hand ("SIOH") respecting the taxpayer was $1.493M, comprised of safe income earned by the taxpayer of $0.976M and safe income of $0.517M in respect of the taxpayer's 50% shareholding of another Canadian corporation ("RTI"). ...

George Weston Ltd. – Tax Court of Canada finds that a cross-currency swap was a hedge notwithstanding no intention to sell underlying indirect U.S. asset

. – Tax Court of Canada finds that a cross-currency swap was a hedge notwithstanding no intention to sell underlying indirect U.S. asset Email this Content As a result of indirect U.S. acquisitions financed with Canadian-dollar debt, the creditworthiness (and stock price) of GWL (a Canadian public company) became susceptible to any substantial depreciation in the U.S. dollar. ... Lamarre ACJ found: if, as here, "it is found that the derivative was used to hedge a capital investment, any gain derived from the derivative will be on capital account" (emphasis added); and the CRA position (see 2013-0481691E5, 2012-0465561I7 and 2011-0418541I7) requiring that a mooted hedge relate to a directly held asset (or liability) and "which denies capital treatment … if there is no sale or proposed sale of the underlying item being hedged … has no legal basis. ... The Queen, 2015 TCC 42, under s. 9 – capital gain v. profit – foreign exchange and General Concepts – Evidence. ...
News of Note post

Life Choice – Tax Court of Canada finds that there can be no SR&ED without testing

12 February 2017- 11:28pm Life Choice – Tax Court of Canada finds that there can be no SR&ED without testing Email this Content A naturopathic products company (Life Choice) reviewed the literature and consulted other researchers in order to devise three new naturopathic formulations. ... The Queen, 2017 TCC 21 under s. 248(1) – scientific research & experimental development. ...
News of Note post

RBC – UK Supreme Court finds that an oil and gas royalty was too remote from a land interest in the oil field to be immovable property under the Canada-U.K. Treaty

12 February 2025- 11:39pm RBC – UK Supreme Court finds that an oil and gas royalty was too remote from a land interest in the oil field to be immovable property under the Canada-U.K. ... Sulpetro has the latter but not the former. … Lady Rose went on to find that even If the rights of the royalty payer (now, BP) had amounted to a right to work the field, nonetheless RBC's right to royalty payments from BP did not amount to a right to "consideration for" such right to work. ... Summaries of Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs [2025] UKSC 2 under Treaties – Income Tax Conventions – Art. 6, Art. 12, General Concepts – Separate Existence, and ETA s. 217 – imported taxable supply- (c). ...
News of Note post

Paletta International – Federal Court of Appeal finds that there is no requirement for the Crown to explicitly plead “sham”

21 September 2021- 11:51pm Paletta International – Federal Court of Appeal finds that there is no requirement for the Crown to explicitly plead “sham” Email this Content Hogan J had found that a tax shelter partnership, which had funded the prints and advertising expenses for films that it had purchased from Twentieth Century Fox, had not incurred such expenses for an income-producing purpose because there was no real prospect that Fox would not exercise its “options” to repurchase the films – and thus no real prospect that the films would generate revenue to the partnership. ... Canada, 2021 FCA 182 under General Concepts – Sham and s. 9 – capital gain v. profit – real estate. ...

Staltari – Tax Court of Canada finds that a property which otherwise might have been held as an adventure in the nature in trade was converted to capital property on donation

7 June 2015- 10:43pm Staltari – Tax Court of Canada finds that a property which otherwise might have been held as an adventure in the nature in trade was converted to capital property on donation Email this Content A commercial real estate broker donated land to the City of Ottawa, received a charitable receipt for its appraised value and claimed that his (substantial) gain was exempted under s. 38(a.2) (respecting "ecological gifts" of capital property). ... The Queen, 2015 TCC 123 under s. 9 – capital gain v. profit – real estate, General Concepts – Evidence, and s. 39(1)(a). ...
News of Note post

CIBC – Federal Court of Appeal confirms that the predominant element supplied by a Loblaw banking sub to CIBC was a right to access Loblaw customers, rather than a financial service

1 October 2023- 11:22pm CIBC – Federal Court of Appeal confirms that the predominant element supplied by a Loblaw banking sub to CIBC was a right to access Loblaw customers, rather than a financial service Email this Content A subsidiary ("PC Bank") of Loblaw had agreed with CIBC for CIBC to provide retail banking services under Loblaw’s President's Choice trademark. ... (r.5) of the financial service definition provided an exclusion from financial service for “property … that is delivered or made available to” CIBC “in conjunction with” CIBC selling financial products of PC Bank, the supply made by PC Bank to CIBC was taxable. ... Canada, 2023 FCA 195 under General Concepts – Res Judicata, ETA s. 309(1) and s. 123(1) – financial service – (r.5). ...

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