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ARQ, 2025 QCCQ 1330-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA The ARQ assessed the taxpayer within two years of the taxpayer’s dissolution pursuant to s. 210(3) of the CBCA. ...

Canada (the King), 2025 FCA 27-- summary under Specified Provincial Input Tax Credit Summary Under Tax Topics- Excise Tax Act- Section 236.01- Subsection 236.01(1)- Specified Provincial Input Tax Credit Ontario electricity suppliers made single supplies of electricity notwithstanding separate regulatory and delivery charges, so that there were full RITCs Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ... In affirming this finding, Boivin JA distinguished Kevin Davis Dentistry, which gave effect to the expressed Parliamentary intent to “provide for different tax treatment of supplies of orthodontic appliances and orthodontic service” (para. 25) whereas, here, the Ontario regulations did “not amount to as clear an indicator of Parliament’s intent as the GST Act did in Kevin Davis Dentistry ” (para. 28). ...

The King, 2023 TCC 45, aff'd 2025 FCA 27-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Bell Canada received single supplies of electricity from its Ontario electricity suppliers Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ... As … noted in City of Calgary, such supplies are parts or components of the single overall supply of electricity. ...

The King, 2025 TCC 36 (Informal Procedure)-- summary under Subsection 334(1) Summary Under Tax Topics- Excise Tax Act- Section 334- Subsection 334(1) application was mailed about a month before it was stamped as received by the CRA mailroom Whether the taxpayer had timely filed his application for the Ontario component of the new housing rebate pursuant to ETA s. 256.21(1) for his newly-renovated home turned on when the substantial renovation had been “substantially completed” (which started the running pursuant to s. 46(6) of the New Harmonized Value Added Tax System Regulations of the two year period for filing the application) and on when the application was filed (which, pursuant to s. 334(1) was deemed to be the mailing date). ... Before allowing the taxpayers appeal, Yuan J stated (at para. 41): I have difficulty imagining what better evidence the CRA could reasonably expect an applicant to produce as proof of filing where the application was submitted by regular mail …. ...

The King, 2024 TCC 9, rev'd in part 2025 FCA 60-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) marrying and caring for the transferor was not consideration for the transfer Two months after their marriage, the taxpayer received (on January 8, 1993) from her 80-year old ailing husband (“CC”) the transfer of a property valued in excess of his subsequently assessed tax liabilities for various taxation years including his 1988 and 1989 years (as a result of losses from a partnership investment being denied). ... A promise to marry that had already been fulfilled by the Appellant at the time of the Transfer cannot be consideration given by the Appellant for the Property at the time of the Transfer. … The Appellant continued to work outside the home after marrying CC and had no special training qualifying her to care for CC in a manner beyond the level of care that might be expected of any spouse. ...

The King, 2025 TCC 47-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) character as shareholder advance or salary is determined by intentions at payment time A small contracting company made regular bi-weekly payments to its two shareholders (Mr. and Mrs. ... He concluded (at para. 27): This is the type of situation … wherein a shareholder receives draws on the shareholder loan account throughout the year and then a dividend determination is made at some point for the year. ...

Canada, 2025 FCA 14-- summary under Paragraph 251(6)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(6)- Paragraph 251(6)(b) s. 251(6)(b) informed the common-law partner definition, which informed “spouse” After the death of her husband, the taxpayer received the proceeds of his RRSP as the designated beneficiary thereof, and transferred those proceeds to her locked-in retirement account. ... Furthermore, since in light of s. 251(6)(b) “a marriage ends on the death of one of the individuals … [t]o have the same rules apply to individuals in a common-law partnership, that relationship would also have to cease upon the death of one of the partners” (para. 44). ...

Agence du revenu du Québec, 2025 QCCQ 378-- summary under Class 29 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 29 contract with detailed specs for provision of concrete, produced by a portable facility at the site of dam construction, was a contract of sale rather than of service The taxpayer (“EMF”), which was a construction company engaged in large civil engineering projects such as roads, bridges and natural gas networks, contracted with Hydro-Quebec (“HQ”) for the furnishing, installation and operation of an on-site portable concrete-producing facility for the provision of the concrete in the installation of a large hydro-electric dam at a remote location. In finding that such a contract should be characterized for as the manufacturing of goods (the concrete) for sale, rather than as a contract of service, Trudel JCQ stated (at paras. 48, 59, TaxInterpretations translation): [T]he evidence shows that the true intention of the parties to the contract was more to ensure, in the construction of the dam, that HQ could obtain supplies of concrete-cement for the purposes of its project to construct “La Romaine 3” power station at all times and continuously, taking into account the challenges linked to the unique conditions of this project. … The Court cannot consider the control measures and contractual requirements of the client as intrinsic characteristics of a service contract, but must rather considers them as representative of HQ's desire to ensure that its supplier would be able to manufacture in sufficient quantity and supply it with concrete-cement in time and place, taking into account the remoteness of its construction site and the extreme geographical and meteorological conditions of a normal construction site. ...