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Re Razzaq Holdings Ltd (2000), 11 BLR (3d) 157, 2000 BCSC 1829-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission In 1992 the two shareholders of a corporation purported to transfer a total of 100 Class A shares and 100 Class B shares equally to two holding companies. ...

Customs & Excise Commissioners, [1997] BTC 5355 (C.A.)-- summary under Business Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Business In finding that the taxpayer, which exercised delegated powers to issue licenses and certificates to its members and exercised public control over those engaged in financial services, auditing and insolvency practice, was not engaged in a "business", Beldam L.J. referred to community jurisprudence that rested on the touchstone of "economic activities" and then stated (at p. 5365): "... ...

Canada (Attorney General), 2012 NSSC 217-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission proposed rectification inconsistent with financial statements The applicant, incorporated by a U.S. corporation ("Fidelity National"), received $23,659,000 from Fidelity National in order to finance its business in Nova Scotia. ...

Canada (Attorney General), 2009 CanLII 18234 (Ont SC)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission unopposed application to reduce capital dividend to CDA balance The directors of the taxpayer mistakenly declared a dividend in an amount exceeding its capital dividend account, and it elected under s. 83(2) to treat it as capital dividend. ...

Ernst & Young LLP, 2015 BCCA 445-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault accounting firm exclusion clause was binding The appellant’s B.C. law firm retained Ernst & Young to provide her with U.S. tax advice in connection with negotiating a separation agreement with her husband. ...

Associated Newspapers Ltd v HM Revenue & Customs, [2017] EWCA Civ 54, [2017] BVC 10-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) acquisition made for free on-supply was part of overhead of a commercial activity A UK newspaper (ANL) paid VAT on its purchase of vouchers from Marks & Spencer and an intermediary ("Hut"), which it then provided free to those readers subscribing to its Sunday editions for the promotional period. ...

Leekes Ltd v HM Revenue & Customs, [2018] EWCA Civ 1185-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) acquired business was segregated from its expanded component A British taxpayer (Leekes) carrying on a retail trade through four stores acquired, for nominal consideration, all the shares of another company (Coles) carrying on a similar retail trade through three stores, and then effectively wound-up Coles so as to carry on the operations of the three former Coles’ stores directly. ... They cannot refer to the enlarged trade carried on by Leekes, because that trade had never been carried on by Coles, and Coles cannot therefore be deemed to have continued to carry it on. … [I]t is necessary to ascribe a deemed continuity to the former trade of Coles, although it now forms part of the merged business carried on by Leekes, and relief may only be obtained if and to the extent that Leekes then derives trading income from the former Coles trade. ...

The Queen, 2019 TCC 166 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development trial and error method or application of metaheuristics were not SR&ED The taxpayer’s software, which determined the optimal timing and sequencing of steps for large construction or mining projects, ceased to work properly with project management software of a large software company (Oracle) after Oracle made poorly documented changes to its code. ...

Canada, 2022 FCA 72-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development need for use of the scientific method in SR&ED In response to the taxpayer’s submission that the Tax Court judge erred in relying on the test from Northwest Hydraulic in that it was not a requirement for SR&ED eligibility that the scientific method be followed, and that the scientific method contemplated by Northwest Hydraulic and applied by the judge differed from the engineering method, Rennie JA indicated: Kam-Press “affirmed that the Northwest Hydraulic criteria are the appropriate interpretation of the definition of scientific research and experimental development in subsection 248(1)” (para. 9). ...

The King, 2023 TCC 18-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development increasing the horsepower of a tractor by 20% was SR&ED Wong J allowed the claim of the taxpayer, which was the only Canadian manufacturer of agricultural tractors, respecting a project to build a four-wheel drive tractor with 85 horsepower (or about 20%) above the current industry maximum. ...