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Re Razzaq Holdings Ltd (2000), 11 BLR (3d) 157, 2000 BCSC 1829-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission In 1992 the two shareholders of a corporation purported to transfer a total of 100 Class A shares and 100 Class B shares equally to two holding companies. ...

Customs & Excise Commissioners, [1997] BTC 5355 (C.A.)-- summary under Business Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Business In finding that the taxpayer, which exercised delegated powers to issue licenses and certificates to its members and exercised public control over those engaged in financial services, auditing and insolvency practice, was not engaged in a "business", Beldam L.J. referred to community jurisprudence that rested on the touchstone of "economic activities" and then stated (at p. 5365): "... ...

Canada (Attorney General), 2012 NSSC 217-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission proposed rectification inconsistent with financial statements The applicant, incorporated by a U.S. corporation ("Fidelity National"), received $23,659,000 from Fidelity National in order to finance its business in Nova Scotia. ...

Canada (Attorney General), 2009 CanLII 18234 (Ont SC)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission unopposed application to reduce capital dividend to CDA balance The directors of the taxpayer mistakenly declared a dividend in an amount exceeding its capital dividend account, and it elected under s. 83(2) to treat it as capital dividend. ...

Ernst & Young LLP, 2015 BCCA 445-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault accounting firm exclusion clause was binding The appellant’s B.C. law firm retained Ernst & Young to provide her with U.S. tax advice in connection with negotiating a separation agreement with her husband. ...

Associated Newspapers Ltd v HM Revenue & Customs, [2017] EWCA Civ 54, [2017] BVC 10-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) acquisition made for free on-supply was part of overhead of a commercial activity A UK newspaper (ANL) paid VAT on its purchase of vouchers from Marks & Spencer and an intermediary ("Hut"), which it then provided free to those readers subscribing to its Sunday editions for the promotional period. ...

Leekes Ltd v HM Revenue & Customs, [2018] EWCA Civ 1185-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) acquired business was segregated from its expanded component A British taxpayer (Leekes) carrying on a retail trade through four stores acquired, for nominal consideration, all the shares of another company (Coles) carrying on a similar retail trade through three stores, and then effectively wound-up Coles so as to carry on the operations of the three former Coles’ stores directly. ... They cannot refer to the enlarged trade carried on by Leekes, because that trade had never been carried on by Coles, and Coles cannot therefore be deemed to have continued to carry it on. … [I]t is necessary to ascribe a deemed continuity to the former trade of Coles, although it now forms part of the merged business carried on by Leekes, and relief may only be obtained if and to the extent that Leekes then derives trading income from the former Coles trade. ...

Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission transaction documents rectified because they did not implement the parties' intention to not trigger Part IV tax Four individuals held their indirect holdings of 10%, 10%, 5% and 5% of the common shares of a Canadian-controlled private corporation (Structures) through three holding companies (the "Holdcos"). ...

Attorney General of Canada, 2013 DTC 5058 [at 5824], 2013 ONSC 781-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission no evidence of instructions to ensure s. 107(2) rollout from trust The taxpayer settled a family trust in 1992 with $5000, which was used to purchase shares in a business corporation. ...

., 2015 QCCA 838, aff'd 2016 SCC 55-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission transactions achieved purpose of neutralizing FX fluctuations and were not intended to avoid FAPI The professional advisors of the respondent ("PJC Canada") recommended two alternatives ("Scenarios 1 and 2") for it to neutralize the effect of foreign exchange fluctuations on the value of its investment in its wholly-owned U.S. subsidiary ("PJC USA"). ...