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Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288-- summary under Section 82 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 82 inconsistent assessments of related taxpayers A Barbados corporation reported substantial profits from the sale of a herbicide to Canadian farmers, and deducted amounts paid to a non-arm’s length Canadian corporation (AgraCity – which was the taxpayer in the case) as service fees. ...

Richards’ guarantee – and as not resulting in any interest in the condo also being supplied by the builder to Ms. ...

Kundahar J, speaking for a panel of two, found that Columbia did not have a permanent establishment, stating (at para. 14): If the petitioner has to purchase goods for the purpose of export, an obligation is cast…to see that the goods…[are] acceptable to the customer outside India…Otherwise, the goods…may not find a customer outside India…[A]ll those acts are necessary to be performed …before export of goods…That liaison office is established only for the purpose of carrying on business of purchasing goods for the purpose of export and all that activity also falls within the meaning of the words “collecting information “ for the enterprise. ...

. … It is however also necessary to take account of the call options purchased by ESIP out of the sum paid by UBS for its subscription for the shares. ...

. … The Minister has discretion in the application of an appropriate exchange rate…and chose to use the annual average exchange rate for 2010 of 1.0562. ...

The Queen, 2015 TCC 138-- summary under Subsection 147(3) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 147- Subsection 147(3) Crown offer of better treatment for one of two years The Crown had made a settlement offer to the taxpayer under which the taxpayer would conced that it was not carrying on an insurance business in Bermuda in 2006, but the Crow would concede that the taxpayer was carrying on business in Bermuda in 2007 – and each party would bear its own costs. ...

Canada, 2016 FCA 181-- summary under Sham Summary Under Tax Topics- General Concepts- Sham deceit of taxpayer was irrelevant to assessment – so that “sham” also was irrelevant The applicant (“Coast Capital”), which was the trustee of RRSPs and RRIFs, was assessed under s. 116(5) for failure to withhold on its purchase of shares (that were taxable Canadian property) of Canadian companies from non-resident vendors at prices which were substantially in excess of those shares' fair market value (with the result that the RRSPs and RRIFs were stripped of funds which ended up in offshore accounts or were applied to pay the fees of the "promoter. ...

D’Auray J noted that this employee had no risk, and Hélie Holdco had no upside as its only assets and liabilities were the prefs and the note, both with frozen values – so that Hélie Holdco essentially was just an accommodation party. ...

. … Given my finding of an offset, the rate is immaterial, however, if such a determination was necessary, I determine the interest rate should be 5.5%, being the rate suggested by the expert. ...

. … [P]aragraph (r.4) will only apply if the service in question is supplied separately from the supply of the financial service that is referred to in any of paragraphs (a) to (i) or (l) of the definition of financial service. ...