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News of Note post
Ahmar – before Strong Forming had to cease operations. In affirming that Mr. Ahmar had not made out the due diligence defence to director liability for failure to remit, Mactavish JA stated: … Mr. Ahmar made the conscious decision to have Strong Forming defer payment of its HST debt, and to use these revenues to satisfy other obligations in the hopes of turning the company’s financial position around. … … Buckingham … state[ed] that the defence under section 323 “should not be used to encourage such failures by allowing a due diligence defence for directors who finance the activities of their corporation with Crown monies on the expectation that the failures to remit could eventually be cured”…. ...
Decision summary
Collins Family Trust v Canada (Attorney General), 2019 BCSC 1030, aff'd 2020 BCCA 196, rev'd 2022 SCC 26 -- summary under Rectification & Rescission
Collins Family Trust v Canada (Attorney General), 2019 BCSC 1030, aff'd 2020 BCCA 196, rev'd 2022 SCC 26-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Fairmont cast doubt on but did not overrule Pallen After noting that the applications before him for the rescission of transactions entailing reliance on an interpretation of s. 75(2) that was established by Sommerer to be incorrect – and that in Pallen “which concerned an almost identical set of facts … rescission was granted” (para. 3), Giaschi J stated (at para. 5): I agree with the submissions of the respondent that the decisions... in Fairmont and Jean Coutu have seriously undermined Pallen. ... [holding] that a tax plan similar to the ones before me (and therefore also similar to the plan in Pallen) constituted abusive tax avoidance and was subject to GAAR. … In Satoma the primary purpose was found by the trial judge to be to avoid payment of any tax…. ...
Current CRA website
Offshore Compliance Advisory Committee – Agenda – June 15, 2016
Offshore Compliance Advisory Committee – Agenda – June 15, 2016 Wednesday June 15, 2016 8:30 a.m. – 4:30 p.m. ... Voluntary Disclosures Program Presentation (30 minutes) Questions & Answers (35 minutes) Joanne Heidgerken 11:45 9. ...
Technical Interpretation - Internal summary
1 February 2018 Internal T.I. 2016-0671921I7 - R&D Services - 95(2)(b) vs 247(2) & 95(3)(b), (d) -- summary under Paragraph 95(3)(b)
1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Paragraph 95(3)(b) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(3)- Paragraph 95(3)(b) R&D services of CFAs not immediately related to the sale of goods by Canco Four U.S. ... After finding that s. 95(2)(b) applied to the R&D Services provided to Canco, the Directorate rejected Canco’s argument that the R&D Services provided to Canco should be considered to be services performed in connection with the sale of goods under s. 95(3)(b), stating: [T]he phrase “services performed in connection with the (...) sale of goods” is limited to services that are directly related to the sales function ….[T]he structure of the phrase refers to activities that are immediately linked or related to the process of selling goods and transferring ownership in the goods from the seller to the purchaser, requiring that the services be directly performed in the actual sale or negotiation process. … [T]he R&D Services … would generally not be immediately linked or related to the process of selling goods and transferring ownership in the goods from the seller to the purchaser. ...
Technical Interpretation - Internal summary
5 April 2018 Internal T.I. 2017-0728581I7 - Ss 125(3.2) & 125(8) amending the business limit -- summary under Paragraph 125(8)(c)
5 April 2018 Internal T.I. 2017-0728581I7- Ss 125(3.2) & 125(8) amending the business limit-- summary under Paragraph 125(8)(c) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(8)- Paragraph 125(8)(c) partner assignment of its SPBL may be amended within the statute-barring period – and can be sliced and diced Does the CRA position (see 2009-0351721E5) that an associated group of Canadian-controlled private corporations can file amended T2 Schedule 23s provided that the amended allocation agreement does not change the amount allocated to any associated corporation for a taxation year for which a reassessment is statute-barred, apply respecting an amended assignment of a partner’s specified partnership business limit? CRA responded: [A] person’s SPBL for a taxation year is the person’s proportionate share of the partnership’s notional small business limit reduced by any amount that the person assigns to a “designated member” … under subsection 125(8). … In general terms, a person that is a member of a partnership can assign all or part of the person’s SPBL to a CCPC if the CCPC is a designated member of that partnership and meets the conditions specified by subsection 125(8). ...
Excise Interpretation
26 November 2002 Excise Interpretation 42421 - AMENDMENT TO LETTER OF We Will Allow Administrative Pre-approval of " " Brand Cigarettes as a Prescibed Brand
26 November 2002 Excise Interpretation 42421- AMENDMENT TO LETTER OF We Will Allow Administrative Pre-approval of " " Brand Cigarettes as a Prescibed Brand Unedited CRA Tags ETA 23.3(1) XXXXX November 26, 2002 Dear XXXXX This letter is further to our previous correspondence to you of XXXXX, concerning your request to have the XXXXX brand XXXXX of cigarettes prescribed as a tobacco brand for the purposes of the export tax and tobacco marking provisions of the Excise Act and Excise Tax Act. ...
Decision summary
Harvest Operations Corp. v. Attorney General of Canada, 2017 ABCA 393 -- summary under Rectification & Rescission
Attorney General of Canada, 2017 ABCA 393-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission cannot use general equitable jurisdiction to do an end run around the narrow (post- Fairmont) rectification doctrine A last-minute requirement of a lender (“ATB”) to the target corporation (“Krang Energy”) for ATBH’s loan to be repaid on closing resulted in the purchase price being reduced by $35M and that amount being lent by an affiliate of the buyer (a predecessor (“Viking Holdings”) to the appellant in this action) to Krang Energy to fund the loan repayment. ... The means that the parties utilized in pursuit of their goal of a tax-neutral transaction – and not the goal of tax neutrality – are the primary focus of a rectification application. ... There is no principled basis, in the guise of exercising our equitable jurisdiction, to pump theoretical steroids into the rectification doctrine and give it the strength or force that the Supreme Court of Canada recently and consistently has declined to do. … ...
GST/HST Ruling
14 August 2012 GST/HST Ruling 85927 - – […] [Supply of Breast Implants]
The Facility has [#] surgeons and […]. 6. The Corporation offers access to a wide range of day care surgeries at the Facility. […] 7. The Corporation describes on its Website […] 8. On its Web site, […] 9. Breast surgery performed by physicians at the Facility includes breast augmentation, reduction and reconstruction procedures. […] 10. […] 11. […] 12. […] 13. ...
Current CRA website
Offshore Compliance Advisory Committee – Agenda – November 17, 2017
Offshore Compliance Advisory Committee – Agenda – November 17, 2017 Friday, November 17, 2017 9:00 a.m.- 4:30 p.m. ... Tax Gaps Presentation Mireille Éthier / André Patry 10:30 5. Break 10:45 6. ... Related Party Initiative Presentation & roundtable discussion Maggie Moscovoy 13:30 9. ...
Current CRA website
Offshore Compliance Advisory Committee – Agenda – June 13, 2017
Offshore Compliance Advisory Committee – Agenda – June 13, 2017 Tuesday, June 13, 2017 8:30 a.m.- 4:00 p.m. ... Welcome & opening remarks Colin Campbell 8:35 2. Administrative items Colin Campbell 9:00 3. ...