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The documentary evidence … does not give any indication that Mr. Chad … intended, in conducting the FX Activities, to achieve a profit/loss amount great enough to offset the $240,000 fee, which was a significant expense …. Thus … the intention of Mr. Chad … in implementing the Trades, was not to earn a profit …. ... The King, 2024 TCC 142 under s. 3(1) – business, and General Concepts- Sham. ...

10 February 2020- 11:56pm Productions GFP – Federal Court declines request for judicial review of a CAVCO reversal of a preliminary ruling Email this Content The appellant (“GFP”) requested a preliminary opinion from the Canadian Audio-Visual Certification Office (CAVCO) as to the eligibility for the Canadian film or video production tax credit of a proposed production that would be in the form of a quiz contest but where the points would not matter and the focus would be on the participants being funny. ... In dismissing GFP’s application for judicial review, Pentney J stated: … [I]t is clear that the opinion provides only a preliminary indication, based solely on the information provided by the producer, and that the final decision is based on an assessment of the actual production itself. … There is nothing in the evidence to suggest that the decision was not made in good faith, that it constituted an abuse of power or that it otherwise violates the objectives of the legislation. … … I accept that in view of the architecture of the system … those who want a certificate must spend money to embark on a production, with no guarantee that they will receive the benefit of a tax credit. ... Canada (Attorney General), 2019 FC 1613 under Reg. 1106(1) – excluded production- (b)(iii). ...

28 January 2020- 11:51pm Muir – Tax Court of Canada finds that s. 160 did not apply to moneys transferred subject to an informal arrangement to discharge liabilities of the transferor Email this Content A professional corporation sold all its assets for $1.2 million, with most of this sum being applied at closing to pay off corporate liabilities, but with the balance of $124,000 being paid to the corporation’s dentist shareholder (Ms. ... He stated: [I]t appears her patients and the Corporation’s creditors would have had legal rights to trace any of the monies involved had the Corporation transferred it to her for any other purpose …. … I do not accept that it was the intention of Parliament or … Livingston to have section 160 apply in circumstances where CRA not only wasn’t but could never be … in any different position whatsoever as a result of the transfer. ...

Duhamel did not employ any system or strategy to manage or mitigate the risks associated with his poker business. … Mr. ... Duhamel does not employ any method of gathering information about his gambling opponents. … … Mr. ... The Queen, 2022 CCI 66 under s. 3(a) – business source. ...