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. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. ...

Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) 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. ...

Leonati, [1996] 3 S.C.R. 458 … at paragraph 51). In the present case, all of the evidence necessary to consider the applicability of subsection 253(b) of the Act was adduced at trial and I am satisfied that the respondent will not be prejudiced by allowing the appellant to raise this argument; it was the respondent who raised at trial the issue of whether the appellant was carrying on business in Canada when the loss on the sale of shares was incurred ...

Of the sums collected, 40% were retained by it as the agreed consideration for its services, and the balance of 60% was paid to the physicians – except that the clinic deducted from this payment to an amount calculated as 7% GST on the (40%) value of its services. ...

Before so concluding, he stated obiter, respecting a Crown argument that it would have been beyond the competence of the Tax Court to (instead) declare that the options were invalid under Quebec law: [T]he role of the TCC, when confronted with an argument based on nullity in the context of an appeal under the ITA, cannot be assimilated to that of a Superior Court which has the power to “declare” a contract to be a nullity for all purposes pursuant to section 33, 35 and 142 of the Code of Civil Procedure … (see in comparison Markou v. ...

. … The judge… did not err in concluding that the supply is not a “financial service” since these [predominant] elements are properly characterized as a payment of an insurance claim for purposes of the inclusion in paragraph (f.1) and as an administrative service for the purpose of the exclusion in paragraph 4(2)(b) of the Regulations. ...

" More interestingly, he also found that in the absence of this Regulation, the service would have been exempt as being for the payment of insurance policy claims – notwithstanding that the Emergis service entailed the provision of taxable supplies described in para. ...

In the Tax Court below, Owen J ultimately found that the charges of Emergis to Great-West for this service were taxable under the Financial Services and Financial Institutions (GST/HST) Regulations, as they were "quintessentially administrative in nature," and also found that, in the absence of this Regulation, the service would have been exempt as being for the payment of insurance policy claims – notwithstanding that the Emergis service entailed the provision of taxable supplies described in para. ...

Canada, 2016 FCA 301-- summary under Section 32 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 32 s. 32 addresses where the prescribed information is timely filed but prescribed form not used D'Arcy J had found that the taxpayer’s late-filing (by six weeks) of Schedule 31 meant that its SR&ED credits for the year in issue were properly denied – even though the information needed to calculate the credits was in its return and on Form 661, which it had filed on a timely basis. ...

The bottom line is that the appellant engaged in RRSP stripping transactions and that is the factual basis relied upon by the Minister in issuing the reassessments …. ...