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24 January 2022- 11:21pm Robillard Estate – Tax Court of Canada finds that MacDonald established that s. 84(2) applied to a speedo pipeline – but doubts MacDonald’s correctness Email this Content An estate engaged in accelerated pipeline transactions in which it transferred shares (stepped up under s. 70(5)) of a portfolio company (“Holdco”) to a Newco in consideration for a note, with Holdco being wound up into Newco a day later – and with the note being repaid by Newco to the estate about three weeks later. ...

6 January 2019- 11:31pm Ihama-Anthony – Tax Court of Canada indicates that an objection can be made after the proposal letter and before the notice of reassessment – but must state “I object” Email this Content Sommerfeldt J found that a fax sent by the taxpayer to CRA could have qualified as notices of objection even though it may have been sent before the issuance of the notices of reassessment in question, stating: Like Justice Woods in Persaud, I am of the view that a notice of objection prepared in response to a proposal letter, which informs a taxpayer that a reassessment is about to be issued, may, if validly served on a Chief of Appeals, constitute a valid notice of objection in respect of the reassessment when it is subsequently issued. ...

27 March 2025- 10:03am 3308367 Canada – Court of Quebec confirms that a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA Email this Content The ARQ assessed the taxpayer within two years of the taxpayer’s dissolution pursuant to s. 210(3) of the CBCA. ...

9 June 2016- 8:17am Uber Canada – Quebec Superior Court indicates that Uber drivers, as "taxi" operators, should have QST-registered – and ARQ officials on a search could seize computers and smart phones for complete copying Email this Content The ARQ obtained a search warrant for searching an Uber Canada office in Montreal. ... ARQ, 2016 QCCS 2158 under ETA s. 240(1.1), ITA s. 231.3(1), General Concepts – Illegality. ...

26 June 2015- 10:16am CRA considers that an estate gift funded by share redemption proceeds – but not by a dividend – generally will satisfy s. 118.1(5.1)(b) Email this Content S. 118.1(5.1)(b) provides the new rules for charitable donations from a (post-2015) graduated rate estate and in most circumstances requires that the donation must be a gift of (i) property that was acquired by the estate on and as a consequence of the death or (ii) property that is substituted for that property. ...

7 July 2025- 12:23am Grenon RRSP – FCA finds that significant distributions of fund units to minors meant that those units had not been lawfully distributed – so that they were not MFTs Email this Content Mr. ... In rejecting this position, Monaghan JA noted that s. 56(1) provides that "there shall be included in computing the income of a taxpayer for a taxation year" the amount described in that section, including "amounts required by section 146 in respect of a [RRSP] … to be included in computing the taxpayer's income for the year," and s. 146(10), in turn, stated that where an RRSP acquired a non-qualified investment, the acquisition date value "shall be included in computing the income for the year of the taxpayer who is the annuitant. ...

23 August 2023- 11:11pm Preston – Federal Court of Appeal finds that assumptions of mixed fact and law were not prejudicial to the taxpayer – and that an FMV assumption instead is factual Email this Content The Tax Court ordered that “assumptions of fact” pleaded by the Crown in its Reply should be struck out and moved to the reasons part of the Reply on the sole ground that they were in fact conclusions of mixed fact and law. ...

14 April 2025- 11:35pm Sura – Court of Quebec finds that the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use Email this Content In 1981, 10 individuals acquired as co-owners two adjoining rental buildings containing a total of 82 apartments. ...