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Article 135(1)(d) of the Principal VAT Directive exempted “transactions, … concerning … payments, transfers, debts, … but excluding debt collection”. ... (a) of the financial service definition, which exempts the “payment … or transfer of money …”.) ... Summary of Target Group Ltd v Revenue and Customs [2023] UKSC 35 under ETA s. 123(1) – financial service – (a). ...

6 December 2018- 12:29am Burton – Federal Court of Australia finds that a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into income Email this Content An Australian-resident individual was taxed at the 15% long-term U.S. capital gains rate on his gains on the disposal of U.S. oil and gas drilling rights. ... The Article does not suggest that a credit is allowed against Australian tax payable for the whole amount of the US tax paid. … It does not prescribe how much is to be allowed as a credit. ... Summaries of Burton v Commissioner of Taxation [2018] FCA 1857 under s. 126(1) and Treaties – Income Tax Conventions – Art. 24. ...

25 August 2019- 11:54pm Burton – Full Federal Court of Australia confirms that a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into taxable income Email this Content An Australian-resident individual was taxed at the 15% long-term U.S. capital gains rate on his gains on the disposal of U.S. oil and gas drilling rights. ... Summaries of Burton v Commissioner of Taxation, [2019] FCAFC 141 under s. 126(1) and Treaties – Income Tax Conventions – Art. 24. ...

7 January 2018- 5:57pm Mac & Mac – Tax Court of Canada denies SR&ED claims because of inadequate notes of the work done Email this Content Mac & Mac was approached by a potential client to use its expertise in hydrodemolition to develop a technique to remove the worn inner linings from pipelines, so that the necessity of replacing them would be eliminated. Mac & Mac used numerous different approaches to applying high-pressure water to this end. In denying Mac & Mac’s SR&ED claims, Graham J stated: Mac & Mac’s claims … do not meet the last test [in Northwest Hydraulic which] … requires Mac & Mac to have kept detailed records of hypotheses, tests and results as the work progressed. … There is simply no way that someone, even someone very experienced in the industry, could hope to replicate or confirm Mac & Mac’s results from [its] notes. ...

7 August 2017- 12:52am Halsall v Champion Consulting – High Court of England and Wales finds that knowledge that advice – that investing in a tax shelter was a “no brainer”- was negligent, commenced when HMRC started investigating Email this Content Investors in a UK charitable gift tax shelter subscribed for shares of a shell company and then, a short number of days later after the shell company had been listed on the AIM, donated their shares to a charity and claimed tax reductions on the basis that the shares had appreciated in value by four times. ... Summary of Halsall & Ors v Champion Consulting Ltd & Ors [2017] EWHC 1079 (QBD) under General Concepts – Negligence. ...

16 May 2017- 12:37am R & S Industries – Tax Court of Canada finds that a taxpayer is not bound by the statement of boot set out in its s. 97(2) election form Email this Content R & S Industries was unsuccessful in a motion to have the Federal Court direct CRA to reconsider its decision to not permit R & S Industries to file an amended s. 97(2) election form so as to change the agreed amounts. ... CRA viewed this as an attempted end-run around R & S’s inability to amend its election, and sought to have the appeal dismissed on jurisdictional grounds. ... Summary of R & S Industries Inc. v. The Queen, 2017 TCC 75 under s. 97(2). ...

As well … procedural gaffes are not so egregious as to require or demand denial of this application. ... Russell J stated in this regard that “there is a semblance of logic to … [the corporation’s] position, sufficient to constitute reasonable grounds.” ... Bureau Barrister & Solicitor Incorporated v. The Queen, 2020 TCC 119 under ETA s. 305(5)(b). ...

28 February 2023- 12:08am K & D Logging – Tax Court of Canada finds that a s. 20(21) deduction cannot offset previously-recognized s. 17 income Email this Content The taxpayer (K & D) initially recognized interest from year to year at the prescribed rate under s. 17 on a loan to a Uruguay farming corporation (Interan) of which it was a 44% shareholder. ... K & D argued that it could obtain a deduction under s. 20(21), for the amount of the interest previously recognized by it, on the loan’s disposition (its partial repayment). ... Summary of K & D Logging Ltd. v. The King, 2023 TCC 23 under s. 20(21). ...

17 December 2019- 12:03am Dow & Duggan – Tax Court of Canada finds that CRA does not have the discretion to stipulate the documentary requirements for direct-shipment export zero-rating Email this Content Sched. ... Summaries of Dow & Duggan Log Homes International (1993) Limited v. ...

28 August 2019- 12:28am Frank A Smart & Son Ltd – UK Supreme Court indicates that input credits were available for fund raising costs of a taxable business Email this Content CRA may take the view that GST/HST costs incurred in raising funds, e.g., through issuing shares or debt, will not give rise to input tax credits in the absence of relief under ETA s. 185(1), because the first order supply being made is an exempt financial service. ... Summary of Revenue and Customs v Frank A Smart & Son Ltd (Scotland) [2019] UKSC 39 under ETA s. 141.01(2). ...