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TCC (summary)
Promutuel Réassurance v. The Queen, 2020 TCC 13 -- summary under Paragraph 256(7)(d)
The MGICs were also the sole members of a non-share corporation (“Groupe Promutuel,” or the “Federation”) which did not have any capital participation in ProRé, and whose affairs were administered by a board of directors consisting of 10 individuals – seven directors and three managing directors of different MGICs. ...
TCC (summary)
Burlington Resources Finance Company v. The Queen, 2020 TCC 32 -- summary under Section 132
Before granting the amendments, D’Auray J indicated that Rule 132 applied only to “formal admissions” such as in pleadings Andersen Consulting ([1998] 1 FC 605 (FCA)) had established “that an application for leave to withdraw admissions did not require a separate form” (para. 75), so that the requested amendment to the Reply could constitute application to withdraw an admission In Burlington’s examination for discovery of the Crown’s nominee in 2014, “[n]umerous times the respondent’s counsel stated that it was the respondent’s position that no amounts were payable as guarantee fees” (para. 77) Although in an Amended Reply, the Crown had admitted that guarantee fees had been paid in the amounts stated in the Notice of Appeal, “the respondent did not make a clear and deliberate concession that the amounts paid to BRI were guarantees fees” (para. 80) in light of the point immediately above and denials made by the Crown elsewhere in the Reply Even if there had been such an admission, D’Auray J “would still have permitted the withdrawal of the admission since … there is a triable issue which ought to be tried in the interests of justice” (para. 82) “In addition, the purported withdrawal does not amount to an injustice to Burlington since it has been aware of the respondent’s position at least since its discovery of the respondent’s nominee in 2014.” ...
FCTD (summary)
Express Gold Refining Ltd. v. Canada (National Revenue), 2020 FC 614 -- summary under Subsection 229(1)
The Minister is under a statutory duty to determine the tax that is owing or a refund is due in relation to the August 2018 return of the Applicant, pursuant to section 275 …. ...
Decision summary
Irish Bank Resolution Corporation Ltd v Revenue and Customs, [2020] EWCA Civ 1128 -- summary under Article 7
In applying the domestic provision, HMRC attributed to the PEs notional additional free capital on the basis that if they had operated as distinct and separate enterprises, they would have had a higher amount of free capital and therefore a correspondingly lower amount of borrowed capital – with the result that HMRC disallowed interest which was actually paid to third parties. ...
TCC (summary)
Lockwood Financial Ltd. v. The Queen, 2020 TCC 128 -- summary under Paragraph 12(1)(b)
Had it been received, “the payment of the 833,333 LEO shares would have been a payment to Lockwood for services rendered [and] hence … business income” (para. 64). ...
FCTD (summary)
Levett v. Canada (Attorney General), 2021 FC 295, aff'd 2022 FCA 117 -- summary under Article 27
It was not improper for CRA to forward to the Swiss authorities a copy of a decision from the Quebec Tribunal administratif des marchés financiers (which CRA had obtained from the AMF) that reproduced allegations raised by the AMF, notably regarding the potential existence of two bank accounts in Switzerland, as CRA had not presented “mere suspicions as facts” and, as it had been provided to them in full, “the Swiss authorities … could appreciate the nature and reliability of the allegations [therein]” (para. 115). ...
FCA (summary)
Kufsky v. Canada, 2022 FCA 66 -- summary under Subsection 160(1)
Webb JA found that the taxpayer was estopped from now arguing that the mooted dividends in fact were not dividends (so that s. 160 did not apply to their payment)- because the appropriate procedures for the declaration and payment of the amounts as dividends were not followed and because s. 38(3) of the Business Corporations Act (Ontario) prohibited the payment of a dividend by an insolvent corporation – on the basis of the application of the principle (based on Wolofsky, 2001 FCA 119) that: [A] taxpayer who has benefited from having an amount included in his or her income as a dividend in a particular taxation year (and who has not objected to the assessment of tax based on having received this dividend) is estopped from claiming in any subsequent appeal related to the application of section 160 of the Act, that the previous filing position was wrong. ...
TCC (summary)
3295940 Canada Inc. v. The Queen, 2022 TCC 68, rev'd 2024 FCA 42 -- summary under Subsection 83(2)
That being the case, the alternative transactions involving the sale of 3295940 shares cannot be submitted for comparison …. ...
TCC (summary)
Axelrod v. The King, 2022 TCC 157 (Informal Procedure) -- summary under Section 11
. … It is even more evident that all aspects of Dr. Axelrod’s reconstruction, in a patient’s mouth, of a significant portion of a tooth, using appropriate filling or restorative materials, were integral components of a composite supply. ...
Decision summary
Hootsuite Inc. v British Columbia (Finance), 2023 BCSC 358 -- summary under Software
Regarding Hootsuite’s access to the EC2 and X3 cloud-computing (”infrastructure as a service”) of AWS), Thomas indicated (at para. 90) that “EC2 creates a virtual machine to provide computing resources to Hootsuite … [that] is opaque to the user- it cannot be manipulated or directly accessed by Hootsuite” and (at para. 98) that “S3 is a hardware storage product in which users install an application program to store and backup data on the virtual machine.” ...