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No. 1238, 2010 ONCA 233-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission corporation included in amalgamation based on mistake The applicant resulted from several corporations being amalgamated in order that the tax losses of some of the predecessor corporations could be accessed. ...

Canada, 2012 DTC 5042 [at at 6770], 2012 BCSC 132-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission 2nd rectification to avoid s. 75(2) taint The petitioners were trustees of a family trust which had been formed in order to permit capital gains on any subsequent sale of the shares of the private company with which the trust had been settled to be allocated amongst the children beneficiaries, thereby multiplying the utilization of the capital gains exemption. ...

.)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The Minister assessed the applicant, a mutual fund manager, on the basis that a payment to it by mutual funds of deferred sale charges received by the mutual funds from redeeming investors represented consideration for taxable supplies of services made by the applicant to the mutual funds. ...

Bramco Holdings Co. (1995), 21 OR (3d) 739 (CA), aff'g (1994), 17 OR (3d) 571 (Gen Div)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rewriting fiscal history Ontario farm lands were transferred to a non-resident corporation for the purpose of utilizing losses of that corporation. ...

Burnet, Duckworth & Palmer, [1993] WWR 374, 8 BLR (2d) 280 (Alta. ... & Mrs. Maplesden) that Mr. Maplesden finance a home purchase through a loan from one of the operating corporations owned by them, that the home be registered in Mrs. ...

., 2012 DTC 5052 [at at 6814], 2012 ONSC 549-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission declaration re character of Ponzi amounts received The applicants and the respondents (which were corporations held by the applicants) were defrauded in a Ponzi scheme. ...

Slipacoff, 2010 ONSC 2693-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission two-year limitations period The defendant and plaintiff held shares in an incorporated dental practice. ...

Minister of Finance, 2008 CanLII 15226 (Ont SCJ), briefly aff'd 2009 ONCA 715-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission A transfer of tangible personal property by an Ontario corporation ("1006") to a second corporation ("QL") would have been exempt from Ontario retail sales tax if QL were a wholly-owned subsidiary of 1006 at the time of the transfer. ...

Commissioners for HM Revenue and Customs, [2013] UKSC 26, [2013] WLR (D) 172-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission mistake re tax consequences justified rescinding settlement of trust The claimant had settled the moneys received as damages for injury to her husband on a discretionary trust of which she and others were trustees. ...

A.G. of Canada, 2015 ONSC 6245-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission reorganization of corporate structure to reflect what it was thought to be at the time of making a tax election The Telus group had a tiered partnership structure. ...