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Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2-- summary under Separate Existence Summary Under Tax Topics- General Concepts- Separate Existence tax code rests on separate existence of each corporation In connection with finding that a right to work an oil field of a UK subsidiary of a Canadian corporation was not a right of the Canadian corporation to work the field, Lady Rose stated (at para. 88): The idea that an "artificial creation of the legislature", namely a company, has a separate legal personality from its shareholders has been protected and reaffirmed from Salomon v A Salomon & Co Ltd [1897] AC 22 onwards. ...

At issue was whether the full assessed amount qualified as an “amount payable, within the meaning of subsection 223(1) of the Income Tax Act … by an individual,” in which case s. 172.1 of the Bankruptcy and Insolvency Act would have been applicable. ...

After referring to the presumption in Re Rizzo & Rizzo Shoes Ltd., [1998] 1 S.C.R. 27, at para. 27 that “the legislature does not intend to produce absurd consequences,” Bourgeois JCQ indicated that the position of Alcoa entailed it both claiming a bad debt deduction for the QST and GST included in the US$16 million and also receiving compensation for those amounts under the L.C. ...

CRA subsequently assessed bcIMC for HST on fees which bcIMC took out of the funds under its administration, on the basis inter alia that ETA s. 267.1(5)(a) deemed the statutory trust impressed on bcIMC’s investments to be a separate (non-Crown) person who thus was not exempt from federal tax – and also on the basis that the investment funds did not belong to bcIMC or the province but, rather, to the pension fund members. ...

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