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Goldcorp Exchange Ltd & Ors v. Leggett & Ors, [1994] UKPC 3, [1995] 1 AC 74-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership no ownership of unascertained goods At the time banks appointed receivers for a dealer in precious metals, the dealer had a stock of precious metal bullion that was substantially less than that which was required to satisfy contracts of the public for purchases of precious metals for future delivery. ...

(Prudential plc & Anor) v. Special Commissioner of Income Tax & Anor, [2013] 2 All ER 309, [2013] UKSC 1-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege In dealing with a claim of privilege asserted with respect to tax advice provided by an accounting firm on a tax shelter transaction, Lord Neuberger stated for the 5-2 majority that, although the rationale for legal advice privilege applies as readily to accountants who provide tax advice as to solicitors or barristers doing the same, such privilege should nevertheless be restricted to lawyers. ...

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) The son of the taxpayer, who was the beneficiary of his own life insurance policy, likely died in 1998 when he was abducted by Angolan rebels, but this was never conclusively established. ...

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ...

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ...

Kucor Construction & Developments & Associates v. Canada Life Assurance Co. (1998), 41 OR (3d) 577 (Ont. ...

Lanman & Kemp-Barclay & Co. of Colombia v. Commissioner of Internal Revenue, 26 TC 582 (1956)-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax The Republic of Colombia levied, pursuant to the same tax statute under which an income tax and an excess profits tax was levied, a capital tax (referred to as a "patrimony tax") which was "based on the theory that the income tax, in order to be an equitable revenue system, requires a tax on capital to more fairly distribute the burdens amongst the nation's taxpayers and to prevent the state from being penalied if a property owner, through negligence or for some other reason, fails to realize the inherent productive potential of his property" (p. 587). ...

Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 documentary demands made by HMRC pursuant to Art. 27 on UK companies being investigated by Australia were valid The Australian Tax Office, which suspected that a UK accounting firm was providing nominee directors and shareholders to UK-incorporated companies to make them look like they were factually resident outside Australia, made a request to the UK Revenue (HMRC) pursuant to Art. 27 of the UK-Australia Treaty (somewhat similar to Art. 24 of the Canada-U.K. ...

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The son of the taxpayers (Mr and Mrs Pope), who was the beneficiary of a life insurance policy which he had purchased on his own life, was abducted in Angola by rebels in 1998. ...

Clyde & Co LLP & Anor v Bates Van Winkelhof, [2012] EWCA Civ 1207-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 partner in partnership cannot be an employee The claimant, who was a solicitor practising as an equity member of a limited liability partnership, and who was expelled as a member, was found not to be a "worker" entitled to protection under the Employment Rights Act 2010 (UK). ...