Search - 润华 最新动态 2025

24 February 2025- 11:59pm Wong – Tax Court of Canada finds engages in a detailed weighing exercise to determine that two ex-spouses were shared custody parents Email this Content After initially denying the Canada child benefit (CCB) claims of the taxpayer in full (on the basis that it was her ex-husband who primarily fulfilled the care responsibilities for their son), CRA assessed her on the basis that they were “shared custody parents,” so that she was entitled to 50% of the CCB amounts. ... The King, 2025 TCC 24 under s. 122.6 – shared-custody parent. ...

10 March 2025- 10:12pm Uppal Estate – Tax Court of Canada strikes pleadings of assumptions of facts in the alternative, and states that it cannot impose a penalty that was not assessed Email this Content Graham J ordered that the Crown’s pleading, that the taxpayer’s purchase of shares of a company occurred “singly or jointly with” a corporation owned by him, should be struck (with leave to file amended pleadings), as acquisition of beneficial ownership by the taxpayer’s company or by him personally were mutually inconsistent, and substantially affected the case he would have to make. ... The King, 2025 TCC 34 under General Concepts – Onus and s. 171(1). ...

31 March 2025- 8:49am Malamute – Tax Court of Canada accepts that cheques to the shareholders labelled as (and treated rather like) “payroll” in fact were shareholder advances Email this Content A small contracting company made regular bi-weekly payments to its two shareholders (Mr. and Mrs. ... He concluded: 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. ... The King, 2025 TCC 47 under s. 5(1). ...

30 April 2025- 3:21am Northbridge – Federal Court of Appeal indicates that it is appropriate to determine ITCs on the basis of global evidence rather than on a supply-by-supply basis Email this Content Northbridge issued around 5,000 insurance policies each year to trucking companies operating in Canada and the US. ... Canada, 2025 FCA 83 under ETA s. 169(1) and s. 141.02(1) – direct input. ...

26 January 2025- 10:48pm Enns – Federal Court of Appeal finds that a widow was not a spouse of her deceased husband Email this Content 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. ... Canada, 2025 FCA 14 under s. 160(1)(a). ...

27 January 2025- 11:31pm Madison Pacific – Federal Court of Appeal finds that Deans Knight applied to a corporate restart plan Email this Content Madison Pacific spun out its existing mining assets so that it was a shell with only tax losses, and then the B.C. real estate companies of two individuals transferred various real estate assets, including jointly owned properties, to Madison Pacific and received shares that resulted in them having a combined total of 46.56% of the votes and 92.82% of the equity. ... Canada, 2025 FCA 20 under s. 245(4) and s. 248(10). ...

1 April 2025- 11:30pm MEGLobal – Tax Court of Canada effectively finds that a taxpayer had no remedy for a refusal of CRA to accept a requested s. 247(10) downward adjustment Email this Content In objections of the taxpayer to reassessments of three of its taxation years to reflect upward transfer pricing adjustments under s. 247(2), it included requested downward adjustments pursuant to s. 247(10). ... The King, 2025 TCC 50 under s. 247(10). ...

30 April 2025- 3:19am Gross – Quebec Court of Appeal finds that a corporation’s controlling shareholder provided services, to fulfil its contractual obligations, qua employee, not independent contractor Email this Content A CPA (Mr. ... Agence du revenu du Québec, 2025 QCCA 492 under s. 5(1). ...

7 April 2025- 11:23pm Total Energy – Federal Court of Appeal confirms that the use of losses of an insolvent public company by a SIFT trust was an abuse of s. 111(5) Email this Content In September 2007, a company (“Nexia”), which traded in loss companies, acquired all of non-voting common shares of an insolvent public corporation (“Biomerge”) (representing 80% of its equity) and 45% of its voting common shares. ... It was also immaterial that s. 256(7)(c)(i) (dealing specifically with a transaction of this type) was added only subsequently (“ Deans Knight … did not look at other provisions enacted after s. 111(5) in order to determine the object, spirit, and purpose of s. 111(5).” ... Canada, 2025 FCA 77 under s. 245(4). ...