Search - 江西农大 毛瑢
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Decision summary
Barker v Baxendale Walker Solicitors (a firm) & Anor, [2017] EWCA Civ 2056 -- summary under Negligence, Fiduciary Duty and Fault
Barker v Baxendale Walker Solicitors (a firm) & Anor, [2017] EWCA Civ 2056-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault tax solicitor was negligent in not advising of the risk of an alternative interpretation Mr Baxendale-Walker, the sole equity partner in a law firm specializing in advising on tax-avoidance schemes, charged the taxpayer (Mr Barker) a fee of £2.4 million in advising on a scheme which Mr Barker implemented with a view to avoiding capital gains tax and inheritance tax respecting his shares of a private company. ... Turning to the negligence issue and in setting the stage, Asplin LJ stated (at paras 59 and 61): …The question is whether in the light of all the circumstances no reasonably competent solicitor in the position of the Respondents would have failed to give the specific warning that there was a significant risk that the EBT arrangement would fail to be tax effective because of the post-death exclusion construction. … …[I]t is perfectly possible to be correct about the construction of a provision or, at least, not negligent in that regard, but nevertheless to be under a duty to point out the risks involved and to have been negligent in not having done so …. In allowing the appeal, Asplin LJ found (at para 71): … [T]here was a significant risk that the … arrangement would not work as a result of the post-death exclusion construction which was centrally important to its structure and the likelihood that the promised tax advantages would be delivered. ...
Current CRA website
Line 12906 – Taxable FHSA income – other
Line 12906 – Taxable FHSA income – other Other taxable first home savings account (FHSA) income includes the following: the amount of taxable distributions that you received in the year as a beneficiary upon the death of an FHSA holder the fair market value of any property in the FHSA that was used as security for a loan any property that remains in the deceased holder’s FHSA at the end of the exempt period you are entitled to as a beneficiary Enter the amount from box 24 and box 28 of all T4FHSA slips. ... Forms and publications Income tax package T4FHSA, First Home Savings Account Statement Related topics Line 12905 – Taxable first home savings account (FHSA) income Line 20805 – FHSA deduction Line 23200 – Other deductions Death and FHSAs Page details Date modified: 2025-01-22 ...
Technical Interpretation - Internal
21 April 2015 Internal T.I. 2014-0560811I7 - FACL carryback Surplus & PAS election
21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2014-056081 FACL carryback Surplus implications, PAS election & application of Bill C-48 transitional rules This is in reply to your correspondence of December 8, 2014, wherein you requested our assistance in respect of the surplus implications of a "foreign accrual capital loss" ("FACL") carryback in the context of a given set of facts. ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (
) if the corporation (
) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (
) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (
) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ...
Old website (cra-arc.gc.ca)
Privacy Impact Assessment (PIA) summary – Personnel Security Screening - Reliability Status + - Security and Internal Affairs Directorate, Finance and Administration Branch
Summary of the project / initiative / change Personnel Security Screening plays a vital role within the Canada Revenue Agency’s (CRA) security program by ascertaining that all employees are appropriately screened based on the access to information and CRA premises required for the performance of their duties. ... As such, in addition to the current reliability status, the CRA’s Security and Internal Affairs Directorate is putting improvements into place through the development of a new level of security screening, Reliability Status +. ... A valid Reliability Status would be a pre-requisite to Reliability Status +. ...
Miscellaneous severed letter
7 January 1992 Income Tax Severed Letter 9134185 - Maintenance payments — adult child — third parties
7 January 1992 Income Tax Severed Letter 9134185- Maintenance payments — adult child — third parties Unedited CRA Tags 60(b), 60(c), 60.1(c), 60.1(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Subject: MAINTENANCE PAYMENTS ADULT CHILD THIRD PARTIES Section(s): 60(b), 60(c), 60.1(c), 60.1(1)] January 7, 1992 Appeals Branch Business and General Appeals & Referrals Division Division K. ...
EC summary
Blauer v. MNR, 71 DTC 5113, [1971] CTC 154 (F.C.T.A.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC) -- summary under Payment & Receipt
.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt post-dated cheque A post-dated cheque was payable for purposes of ss. 12(1)(l) and 76(1) on its date rather than the date of delivery. ...
Decision summary
Narich Pty. Ltd. v. Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC) -- summary under Payment & Receipt
Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt indirect receipt of wages An argument was rejected to the effect that fees received by employees of a company were not wages because they were collected directly from clients of the company. ...
FCTD (summary)
Western Union Insurance Co. v. The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD) -- summary under Payment & Receipt
The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt sending of cheque to sender's lawyers The sending of a cheque by the lender to (its) solicitors did not constitute the payment of a sum to the borrower. ...
TCC (summary)
Transalta Corporation v. The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86 -- summary under Payment & Receipt
The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...
FCTD (summary)
The Queen v. Ans, 83 DTC 5038, [1983] CTC 8 (FCTD) -- summary under Payment & Receipt
Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by set-off A company's shareholder was held to have received a bonus when the amount of the bonus payable by the company was credited against the balance outstanding on the loan by the company to the shareholder. ...