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6 December 2016- 11:26pm KPMG – Federal Court of Canada finds that s. 231.2(3) overrides the CPA duty of maintaining client confidentiality Email this Content KPMG LLP sought to quash an order that authorized CRA to impose a requirement on it pursuant to s. 231.2(3) to disclose confidential information respecting unnamed clients who had participated in the KPMG “Offshore Company Structure” – on the grounds that the CPA Code of Professional Conduct prohibited disclosure of confidential client information. ...

5 June 2017- 12:23am Persepolis – Tax Court of Canada declines to infer the existence of an agency arrangement Email this Content A company (“Persepolis”), which had been incorporated to do renovation work on a cost plus 15% basis on a building owned by a corporation whose shareholder was friends with its sole shareholder, was found not to have incurred its renovation costs as agent for that owner in the absence of convincing evidence that the owner “had implicitly accepted an agency relationship with respect to the renovations.” ... The Queen, 2017 TCC 89 under General Concepts – Agency. ...

3 January 2018- 8:15am Lavrinenko – Tax Court of Canada finds that 40/60 is not “near equal” Email this Content The definition for Canada child benefit purposes of a “shared-custody parent” refers inter alia to a parent residing with the child “on an equal or near equal basis”. ... The Queen, 2017 TCC 230 under s. 122.6 – shared-custody parent. ...

28 March 2018- 1:04am Westsource – Federal Court of Appeal finds that a materially incomplete T661 resulted in a denied SR&ED claim Email this Content Boxes 240, 242 and 244 of the prescribed SR&ED form (T661) filed by the taxpayer were left blank. ... In affirming this finding, Woods JA stated that while there is a “legislative objective of encouraging research and development activities … another objective is to facilitate tax administration by denying the tax incentives if the filing requirement has not been satisfied.” ...

22 November 2018- 4:43am Tournier – Tax Court of Canada finds that file storage fees incurred after business cessation were deductible Email this Content A retired member of Nova Scotia bar was permitted to deduct $1200 of annual storage fees for client files notwithstanding that her practice had ceased two years’ previously. After noting that retention of the client files was professionally recommended, Bocock J stated that deductibility was “consistent with the notion of unavoidable expenses necessarily expended in future years referable to previous income contemplated in … Poulin, Raegele and Langille.” ...

27 May 2019- 12:05am Roofmart Ontario – Federal Court authorizes a CRA requirement for a construction material company to disclose its customers with significant purchases Email this Content Campbell J authorized a requirement by the Minister for Roofmart to disclose the particulars of all its customers who in any of the past 4 ½ years had made purchases of construction materials from Roofmart in excess of an annualized total of $20,000. ...

4 October 2019- 1:10am Miller – Tax Court of Canada accepts that software was to be valued at its purchase price Email this Content A PhD purchased software from a promoter entity in 2003 for $7,000 and immediately donated it to a registered charity, and was issued a tax receipt for $42,000. ... The Queen, 2019 TCC 204 under s. 118.1(1) – total charitable gift. ...

25 February 2020- 12:08am Dilalla – Federal Court of Appeal articulates the purpose of the fresh start rule Email this Content Rennie JA confirmed the decision below that the “fresh start” rule (Rule 8) precluded the taxpayer from bringing a motion to strike the Crown’s Reply more than two years after all pre-trial proceedings had been completed, stating: The fresh step rule is designed to ensure the orderly movement of litigation through to trial. ... Here, the judge’s discretion was exercised consistent with the objective of this rule …. ...

8 March 2022- 11:23pm Foley – Tax Court of Canada finds that the non-inclusion of surrogate parent expenses under s. 118.01 did not violate s. 15 equality rights Email this Content The taxpayer unsuccessfully claimed that the exclusion from the scope of the adoption tax credit (“AETC”) under s. 118.01 of various expenses he incurred in connection with having a surrogate mother bearing a child, derived from an embryo from him and his wife, infringed his equality rights under s. 15 of the Charter. ... The Queen, 2021 TCC 92 under Charter – s. 15. ...

20 June 2022- 11:29pm CRA indicates that it initially imposes instalment interest on VDP-accepted wash transactions “given … system limitations” Email this Content Where CRA accepts a voluntary disclosure for a wash transaction, and grants full relief for penalties and interest on the amounts the supplier otherwise should have collected and remitted, instalment interest nonetheless will be applied respecting the periods covered by the voluntary disclosure given CRA’s “system limitations” – although CRA indicated that such interest likely would then be cancelled, and stated: Internal discussions are currently underway on the processing and policies on the waiving of instalment interest with the Voluntary Disclosures Program. ...