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No. 1238, 2010 ONCA 233-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission corporation included in amalgamation based on mistake The applicant resulted from several corporations being amalgamated in order that the tax losses of some of the predecessor corporations could be accessed. ...

Canada, 2012 DTC 5042 [at at 6770], 2012 BCSC 132-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission 2nd rectification to avoid s. 75(2) taint The petitioners were trustees of a family trust which had been formed in order to permit capital gains on any subsequent sale of the shares of the private company with which the trust had been settled to be allocated amongst the children beneficiaries, thereby multiplying the utilization of the capital gains exemption. ...

.)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The Minister assessed the applicant, a mutual fund manager, on the basis that a payment to it by mutual funds of deferred sale charges received by the mutual funds from redeeming investors represented consideration for taxable supplies of services made by the applicant to the mutual funds. ...

Bramco Holdings Co. (1995), 21 OR (3d) 739 (CA), aff'g (1994), 17 OR (3d) 571 (Gen Div)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rewriting fiscal history Ontario farm lands were transferred to a non-resident corporation for the purpose of utilizing losses of that corporation. ...

The Queen, 2015 DTC 1109 [at at 638], 2015 TCC 77-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development incremental improvements to an already-launched device were experimental development After developing and commercially launching a miniature portable printer, the taxpayer pulled the product in 2009 after identifying problems with curling paper and battery life. ...

The Queen, 2015 TCC 32-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development feed for cattle to be used for beef after SR&ED testing was excluded The taxpayer, a veterinary consulting firm, undertook four research projects to test new diets, supplements, and vaccines on cattle, and paid feedlot operators to perform these protocols. ...

The Queen, 2012 DTC 1149 [at at 3339], 2012 TCC 133 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Woods J. found that it was not reasonable for the taxpayer, a professional corporation belonging to Dr. ...

Burnet, Duckworth & Palmer, [1993] WWR 374, 8 BLR (2d) 280 (Alta. ... & Mrs. Maplesden) that Mr. Maplesden finance a home purchase through a loan from one of the operating corporations owned by them, that the home be registered in Mrs. ...

., 2012 DTC 5052 [at at 6814], 2012 ONSC 549-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission declaration re character of Ponzi amounts received The applicants and the respondents (which were corporations held by the applicants) were defrauded in a Ponzi scheme. ...

Slipacoff, 2010 ONSC 2693-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission two-year limitations period The defendant and plaintiff held shares in an incorporated dental practice. ...