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The facts are somewhat analogous to those in Global Cash Access, where Global was charged for something analogous to cheque-cashing services by the casino in fee amounts ranging from 12.5% down to 2.5%, depending on the size of the individual amounts – with Sharlow JA finding that these were for exempt encashment services. One distinction might be that it would have been less consonant with the “economic realities” (to use a phrase of Richards LJ) to characterize these amount as being paid by Global for access to the casino – and another, that the amounts were high, but not outrageous, when viewed as consideration only for encashing. ... Summary of Wiltonpark Ltd & Ors v Revenue & Customs Commissioners, [2016] EWCA Civ 1294 under ETA s. 123(1) – financial service – para. ...
News of Note post
Maso – Privy Council confirms application of minority discount to minority bloc of public-company shares Email this Content Some minority shareholders of a Caymans NASDAQ-quoted company dissented when they were squeezed out in a going-private transaction for a modest (26%) premium over the trading price. ... Summary of Shanda Games Ltd v Maso Capital Investments Ltd & Ors (Cayman Islands) [2020] UKPC 2 under General Concepts – FMV – shares. ...
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30 May 2021- 11:26pm Mussalli – Full Federal Court of Australia finds that “rent prepayments” made by new franchisees to reduce percentage rent payments on leases were capital expenditures Email this Content Two Australian trusts that were to be the franchisees for seven McDonald’s restaurants agreed, at the same time as they agreed to enter into leases of the premises for base rents plus sales-based percentage rents, to make a lump sum “prepayment of rent” so as to reduce the percentage rent payable. ... In finding that the rent prepayments were capital expenditures, so that such deduction was not permitted, Mckerracher and Stewart JJ stated: There is no principle that a payment that substitutes for future revenue outgoings or which compensates for them, or which more accurately in this case obviates or removes the need for them, must itself be revenue. … [I]f the term … of the lease was irrelevant to the method of calculation of the payment [as was the case here], then any argument that the payment was in truth … a computation of prepayment of rent is extremely difficult to mount. … The taxpayer has, in effect, purchased the right to have the better lease with the lower rent. … Neal Armstrong. Summary of Mussalli v Commissioner of Taxation [2021] FCAFC 71 under s. 18(1)(b) – Capital expenditure v. expense – Contract purchases or prepayments. ...
News of Note post
7 November 2021- 11:43pm CIBC – Tax Court of Canada finds that s. 39(2) historically applied only to FX gains or losses on liabilities and foreign currency dispositions Email this Content CIBC realized an FX loss of C$126.4 million in 2007 when shares of a US subsidiary for which it had subscribed US$1 billion were redeemed for US$1 billion. ... Furthermore, Owen J disagreed with the CIBC position, stating: [S]ubsection 39(2) was not required to address foreign currency fluctuations associated with acquisitions and dispositions of property other than foreign currency because subsection 40(1) read with due regard to the need to convert the amounts identified in that subsection into Canadian dollars already addressed such fluctuations and integrated them into the gain or loss computed under subsection 40(1). … [T]his fact and the fact … that extending subsection 39(2) to dispositions of property other than foreign currency raises difficult issues together strongly suggest that Parliament did not intend that subsection 39(2) apply to dispositions of property other than foreign currency. … In conclusion … subsection 39(2) as it read in 2007 was a stand-alone provision but Parliament did not intend that the subsection apply to dispositions of property other than foreign currency. ... The Queen, 2021 TCC 71 under s. 40(3.6), General Concepts – Stare Decisis and Statutory Interpretation – Prior Cases. ...
News of Note post
13 December 2022- 11:10pm Abedipour – Tax Court of Canada finds that a house construction not being an adventure in the nature of trade was corroborated by its custom design features Email this Content Whether the taxpayers were required to charge HST on the sale of their newly-constructed home turned, under para. ... This strongly suggests that they built the home only for themselves. … [T]he Appellants left nothing for a potential purchaser to customize. … The fact that the Appellants finished everything to their own personal taste strongly suggests that they built the home only for themselves. ... The King, 2022 TCC 155 under ETA s. 123(1) – builder – para. (f). ...
News of Note post
CIBC perhaps should have succeeded on the first argument – but did not, because two things went against it. ... Based on his finding that CIBC received a taxable service, it was unnecessary for Visser J to consider the second argument – but he did anyway, and found that the Aeroplan Miles did not qualify as gift certificates, stating: Parliament intended a gift certificate to be an equivalent to money, and to have attributes similar to money. … Aeroplan Miles … fatally... do not have a stated monetary value. ... The Queen, 2019 TCC 79 under ETA s. 123(1) – supply, s. 123(1) – service, s. 181.2. ...
News of Note post
20 June 2022- 11:30pm Marino – Federal Court of Appeal confirms the Oceanspan principle that a non-resident who does not compute income from any source for ITA purposes does not have a taxation year Email this Content An individual with no connection to Canada paid significant tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his “unused” tuition tax credits as a deduction from Canadian tax. ... In the Court of Appeal, Stratas JA stated (at para. 3) that “ Oceanspan is … directly on point … [and] binds us, just as it bound the Tax Court,” and further rejected the taxpayer’s argument- that s. 250.1 supersedes Oceanspan and has the effect of deeming every non-resident person to have a taxation year in Canada – and expressed agreement here as well with the Tax Court’s reasons. ... Canada, 2022 FCA 115 under s. 248(1) – taxation year, and s. 250.1(a). ...
News of Note post
Pre-production mine development expenses that qualify under CEE – (g.4) need not qualify under (g.3)
3 December 2017- 7:30pm Pre-production mine development expenses that qualify under CEE – (g.4) need not qualify under (g.3) Email this Content Para. ... Summary of 11 October 2017 Internal T.I. 2017-0719181I7 F under s. 66.1(6) – CEE – para. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Chapter 7: Page 8 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 7: Page 8 of the T2 return On this page... Part I tax Line 550 – Base amount of Part I tax Line 560–Additional tax on personal services business income Line 602 – Recapture of investment tax credit (ITC) Scientific research and experimental development Child care spaces Line 604 – Refundable tax on CCPC's investment income Line 608 – Federal tax abatement Line 616 – Manufacturing and processing profits deduction Lines 620 and 624 – Investment corporation deduction Line 628 – Additional deduction – credit unions Line 632 – Federal foreign non-business income tax credit Line 636 – Federal foreign business income tax credit Continuity of unused federal foreign business income tax credits Carryback or carryforward of unused credits Lines 638 and 639 – General tax reduction Line 640 – Federal logging tax credit Line 641 – Eligible Canadian bank deduction under section 125.21 Line 648 – Federal qualifying environmental trust tax credit Line 652 – Investment tax credit Available-for-use rule Investments and expenditures that qualify for an ITC Activities that qualify for an ITC on qualified property Scientific research and experimental development (SR&ED) qualified expenditure pool SR&ED investment tax credit and refund Apprenticeship job creation tax credit Investment tax credit (ITC) for child care spaces Investment tax credit (ITC) claim When to complete Schedule 31 Investment tax credit refund Part I tax payable Part I tax Line 550 – Base amount of Part I tax The basic rate of Part I tax is 38% of taxable income. ... Use Schedule 31, Investment Tax Credit – Corporations, to calculate the ITC. ...
Scraped CRA Website
T2 Corporation – Income Tax Guide – Chapter 7: Page 8 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 7: Page 8 of the T2 return On this page... Part I tax Line 550 – Base amount of Part I tax Line 560–Additional tax on personal services business income Line 602 – Recapture of investment tax credit (ITC) Scientific research and experimental development Child care spaces Line 604 – Refundable tax on CCPC's investment income Line 608 – Federal tax abatement Line 616 – Manufacturing and processing profits deduction Lines 620 and 624 – Investment corporation deduction Line 628 – Additional deduction – credit unions Line 632 – Federal foreign non-business income tax credit Line 636 – Federal foreign business income tax credit Continuity of unused federal foreign business income tax credits Carryback or carryforward of unused credits Lines 638 and 639 – General tax reduction Line 640 – Federal logging tax credit Line 641 – Eligible Canadian bank deduction under section 125.21 Line 648 – Federal qualifying environmental trust tax credit Line 652 – Investment tax credit Available-for-use rule Investments and expenditures that qualify for an ITC Activities that qualify for an ITC on qualified property Scientific research and experimental development (SR&ED) qualified expenditure pool SR&ED investment tax credit and refund Apprenticeship job creation tax credit Investment tax credit (ITC) for child care spaces Investment tax credit (ITC) claim When to complete Schedule 31 Investment tax credit refund Part I tax payable Part I tax Line 550 – Base amount of Part I tax The basic rate of Part I tax is 38% of taxable income. ... Use Schedule 31, Investment Tax Credit – Corporations, to calculate the ITC. ...