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Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return On this page... Identification Signing up for online mail when filing your T2 return Line 001 – Business number (BN) Line 002 – Corporation's name Lines 010 to 018 – Address of head office Lines 020 to 028 – Mailing address Lines 030 to 038 – Location of books and records Lines 040 and 043 – Type of corporation at the end of the tax year Lines 060, 061, 063, 065 – To which tax year does this return apply? ... Line 079 – If an election was made under section 261 Lines 080 to 082 – Is the corporation a resident of Canada? ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return On this page... Identification Signing up for online mail when filing your T2 return Line 001 – Business number (BN) Line 002 – Corporation's name Lines 010 to 018 – Address of head office Lines 020 to 028 – Mailing address Lines 030 to 038 – Location of books and records Lines 040 and 043 – Type of corporation at the end of the tax year Lines 060, 061, 063, 065 – To which tax year does this return apply? ... Line 079 – If an election was made under section 261 Lines 080 to 082 – Is the corporation a resident of Canada? ...
Decision summary
Ingenious Games LLP & Ors v Revenue and Customs, [2021] EWCA Civ 1180 -- summary under Section 96
" In making its “with a view to profit” determination, the Court noted that the following principles generally were common ground: [S]haring profits … [is] not an essential characteristic of a partnership [citing Young v. ... It follows that the complex mosaic of generally accepted accounting practice … will generally have little part to play. Fourth … the view to profit need not be the predominant subjective purpose, but it must be part of the partners' subjective purpose. ...
Decision summary
Harvest Operations Corp v. A.G. (Canada), 2015 DTC 5067 [at at 5904], 2015 ABQB 327 -- summary under Rectification & Rescission
(Canada), 2015 DTC 5067 [at at 5904], 2015 ABQB 327-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission requested rectification order to fix bump did not match parties' specific plan at closing The Bump Mistake A predecessor in interest of the applicant ("Viking") entered a multi-step acquisition and restructuring transaction to acquire an arm's length corporation ("Krang"). ... Dario J dismissed the taxpayer's application, stating (at paras. 77, 81 and 82): [T]his is not a case of the parties "wrote it down wrong", but rather the parties got it wrong. … To the extent we are talking only about the increased bump room due to the Krang Debt, the evidence does not establish that the inability to benefit from this tax treatment would have terminated the acquisition, or that the common intent of the parties that drove them to the formation of the transaction was frustrated. … The intent to complete a transaction in the most tax efficient manner possible is not sufficiently specific. ...
Decision summary
BLP Group plc v Commissioners of Customs & Excise, [1995] EUECJ C-4/94 (ECJ (5th Chamber)) -- summary under Supply
BLP Group plc v Commissioners of Customs & Excise, [1995] EUECJ C-4/94 (ECJ (5th Chamber))-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply mere borrowing of money is not a supply BLP was a management holding company which provided services to a group of trading companies producing goods for use in the furniture and DIY industries. ... In finding that taking out a loan did not involve a VATable transaction by the borrower at all, even if it pays interest (it was the mere recipient of a service provided by the lender) the Court stated (at para. 47): The taking up of a loan and the selling of an interest in a company are not … operations of the same type for the purposes of the VAT system — nor are they, moreover, for an undertaking's operational purposes, since the income from the sale of shares is part of the undertaking's own resources, whereas the loan is part of its borrowed resources — because that system focuses on transactions and makes a clear distinction between taxable and exempt transactions. ...
Current CRA website
Offshore Compliance Advisory Committee – Minutes – August 3, 2016
Offshore Compliance Advisory Committee – Minutes – August 3, 2016 Wednesday, August 3, 2016 List of Participants OCAC Members Chair Colin Campbell Vice-Chair Kimberley Brooks Committee Members Marie-Pierre Allard Catherine Brown Larry Chapman Allan Lanthier (by phone) Daniel Thornton CRA Attendees Deputy Assistant Commissioner, International, Large Business and Investigations Branch Lisa Anawati Special Advisor, International, Large Business and Investigations Branch Alexandra MacLean 1. ... VDP recommendations – next steps CRA committed to obtaining answers to questions the Committee had about VDP operations and will consider possible options for point f) above. ...
News of Note post
31 January 2021- 11:01pm Prairies Tubulars – Federal Court finds that requiring payment of duties before they could be appealed was not unconstitutional Email this Content Prairies Tubulars challenged the constitutionality of provisions of the Special Import Measures Act (the “Appeal Payment Provisions”) which required it to pay all outstanding duties before proceeding with the SIMA’s appeal procedure. ... Before dismissing the application, Ahmed J stated: [L]egislation may be inconsistent with section 96 … if it creates financial obstacles that impose undue hardship on potential litigants …. However, in light of the Applicant’s gross earnings … I am not persuaded … that the Appeal Payment Provisions cause it undue hardship. … Trial Lawyers is distinguishable … because the Appeal Payment Provisions are remedial, not punitive. ...
TCC (summary)
Life Choice Ltd. v. The Queen, 2017 TCC 21 (Informal Procedure) -- summary under Scientific Research & Experimental Development
The Queen, 2017 TCC 21 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development no SR&ED without testing The taxpayer was a natural health product company. ... Dahl that is fatal to this appeal. … Boyle J further stated (at para 53): My decision in this case is in no way intended to suggest that literature reviews and consultations with other researchers cannot be qualifying activities giving rise to qualifying expenses as legitimate constituent parts of SR&ED activities. … ...
FCA (summary)
KAM-PRESS METAL PRODUCTS LTD. v. HER MAJESTY THE QUEEN, 2021 FCA 88 -- summary under Scientific Research & Experimental Development
HER MAJESTY THE QUEEN, 2021 FCA 88-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development requirement for use of the scientific method in SR&ED The taxpayer acknowledged that the work performed by it for which it claimed investment tax credits did not follow the scientific method as described in Northwest Hydraulic, but argued (at para. 6) that “there was no reference to ‘scientific method’ in the text of the definition [of SR&ED]” and, therefore, that requirement should not have been applied to it. In rejecting this submission, Webb JA stated (at para. 8): Kam-Press did not address any … decisions of this Court [endorsing the criteria set out in Northwest Hydraulic] or provide any basis upon which these cases should not be followed. There is no basis to overturn Northwest Hydraulics or the decisions of this Court that have adopted the approach to be followed, as set out therein, to determine if a particular project or activity qualifies as SR&ED. … ...
TCC (summary)
Emotion Picture Studios Inc. v. The Queen, 2015 TCC 323, 2016 DTC 1005 [at 2519] (Informal Procedure) -- summary under Scientific Research & Experimental Development
The Queen, 2015 TCC 323, 2016 DTC 1005 [at 2519] (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development experiments to maximize internet search rankings were not SR&ED The taxpayer was engaged in determining how on-page and off-page variables for websites interrelate to determine their Google (or other internet search engine) ranking and how to structure data to improve such ranking. In finding that this activity did not qualify as SR&ED, C Miller J stated (at para. 9) that “the experiments of submitting several different versions of websites to determine the significance of variables relies on existing technology in a routine manner,” and (at para. 10): Here, the advancement would be the determination of algorithms that relate variables for purposes of ranking sites. … I fail to see how it is a scientific advancement to figure this out. ...