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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. ...

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. ...

. … [T]he treatment accorded to other productions does not create legitimate expectations for the respondent. ...

After finding (at para. 45) that “subsection 3(h) is ultra vires in so far as it applies to alcoholic beverages,” and in concluding that the respondent was entitled to a rebate based on the 19% rate if tax actually imposed rather than the 8.1% rate in s. 3(h), Noël J.A. stated (at para. 68): The purpose of the Act in this case is … clear. ...

In his dissenting reasons, Pelletier JA referred inter alia to s. 67(2) of the Bankruptcy and Insolvency Act, which reflected an intention that “Parliament put the Crown on the same footing as unsecured creditors” in a bankruptcy” – with an exception for employee source deductions, which “is explained by the fact that source deductions are amounts which belong to the employee in question…[and] this money does not belong to the employer anymore” (paras. 73-74). ...

. … The gravamen of the offence under subsection 163(2) is making of a false statement, knowing (actually or constructively, i.e., through wilful blindness) that it is false. ...

In my view, in the circumstances of this case, [the appellants] had sufficient common interest in the transactions to warrant a finding that, in Alberta or British Columbia, the … memo is protected from disclosure by solicitor-client privilege. ...

Canada, 2018 FCA 74-- summary under Tax Benefit Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(1)- Tax Benefit tax benefit to trust from tax-free dividend even though not distributed to a beneficiary In order to strip surplus of an operating corporation (“Gennium”) controlled by the Pilon family, a dividend paid by Gennium was distributed through a series of transactions to a corporation with no assets (“9163”), which then paid the amount to a Pilon family trust (“Satoma Trust” – which also had a corporate beneficiary) as a dividend on special shares that Satoma Trust held in 9163. ...

. $19M in fees paid to a French lobbyist firm, whose purpose “was to facilitate the implementation of the Pechiney transaction by heading off possible political and public relations issues which might derail the transaction, given Pechiney’s special status … in France” (para. 29), fell into the implementation cost category, and were capital expenditures. ...

He was aware of the hedging effect which the Forward Contract would have on the BNS shares …. ...