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AGC, 2023 ONSC 6193-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission family trust deeds rectified to reflect the drafting contemplated in the original tax plan The two applicant trusts were formed in order to acquire the common shares of a corporation (“Signature”) in an estate freezing transaction. ...

Skatteforvaltningen (the Danish Customs and Tax Administration) v Solo Capital Partners LLP & Ors, [2023] UKSC 40-- summary under Revenue Rule Summary Under Tax Topics- Statutory Interpretation- Revenue Rule revenue rule and sovereign authority rule did not apply where the foreign authority was suing to recover stolen money rather than to recover taxes The respondent, which was the Danish Customs and Tax Divisions (“SKAT”) brought claims in an English civil court seeking to recover £1.44 billion which it had paid based on allegedly fraudulent claims for refunds of Danish dividend withholding tax – SKAT alleged that most of the appellants (“Solo Capital”) had fraudulently misrepresented that they, as shareholders of Danish companies, had been subject to withholding at a rate in excess of the Treaty-reduced rate on dividends when, in fact, they never had held any shares in any of the relevant Danish companies. ...

Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business deer-hunting activity was a business based on the taxpayer's subjective intention of generating a profit Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade … or undertaking, or any other income earning activity, carried on with a view to profit. ...

Cassels Brock & Blackwell LLP, 2013 ONCA 165, rev'g 2012 DTC 5013 [at 6604], 2011 ONSC 6724-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault potential problem did not engage limitations period The plaintiff, along with about 900 other taxpayers, indirectly acquired rights to timeshare weeks at a Carribean resort, and donated the rights to a Canadian athletic association along with enough cash to discharge encumbrances on the timeshare weeks. ... The limitations period could not commence until the claim was discoverable, and a mere " potential problem" does not make a claim discoverable. ...

(Re), 2014 BCSC 1791-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission failure to file timely tax returns did not invoke the dirty hands bar to equitable rescission In 2011, the petitioners conveyed undeveloped B.C. lands to a limited partnership with an affiliated general partner. ...

Re: Pallen Trust, 2014 DTC 5039 [at at 6726], 2014 BCSC 305, aff'd 2015 BCCA 222-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rescission due to unexpected caselaw development An individual ("Pallen") or his spouse ("Tonn") settled the taxpayer, a family discretionary trust, and transferred his shares of "New Integrated" to a personal holding company ("Pallen Holdings") in exchange for shares under s. 85(1). ...

Arora, [2010] CTC 139, 2009 ABQB 656 (Alta QB)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission A corporation ("Stone's") had entered into an agreement in 1996 to purchase lands for $500,000. ...

MNR, 2014 ONSC 4983-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission clarification that directions to a trustee shareholder were to be made by the mooted CCPC's board rather than a non-resident executive The applicant ("K-Can") was intended to qualify as a Canadian-controlled private corporation. ...

A.G of Canada, 2015 DTC 5128 [at at 6378], 2015 ONSC 281, rev'd 2018 ONCA 562-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification transactions to avoid s. 98(5) rollover contained 2 more transactions than in original plan In order that the applicant ("CLICC") could realize an accrued capital loss on its 99% limited partner interest in a subsidiary limited partnership ("MAM LP") (and following preliminary dividends): On December 7, 2007, MAM LP distributed an asset to CLICC and a wholly-owned subsidiary of CLICC ("CLICC GP") based on their respective 99% and 1% interests. ...

., 2015 ONSC 7189-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission stock option deduction was peripheral to the larger share sale transaction The general partner of an Ontario limited partnership (“Atria”) granted stock options on its Class C shares to 10 Atria executives. ...