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., 2015 ONSC 7189-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission stock option deduction was peripheral to the larger share sale transaction The general partner of an Ontario limited partnership (“Atria”) granted stock options on its Class C shares to 10 Atria executives. ...

Agence du revenu du Québec, 2018 QCCQ 786-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission taxpayer could reverse an assessment for a taxable benefit by subsequently engaging in self-help rectification On August 15, 2007, Mr. ...

Canada (Attorney General), 2022 BCSC 796-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission declaration made by the parties that their contribution was annulled under Dutch law appeared to have retroactive effect The petitioners were a Dutch cooperative (“Heinz Co-op”) and a B.C. unlimited liability company (“KH Canada”) which was the sole member of Heinz Co-op and the subsidiary of a U.S.- resident corporation. ...

Revenue Commissioners v Susquehanna International Group Ltd & ors, [2025] IECA 123-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a US LLC was not a resident of the US for purposes of the US-Ireland treaty The taxpayers were Irish resident companies, which were part of a group whose ultimate parent was a single member LLC (“SIH LLC”), which was fiscally transparent for U.S. tax purposes. ... " Allen JA stated (at para. 42) that, as “the purpose of the treaty is to avoid double taxation … it stands to reason that it should only apply to persons who otherwise would be exposed to a liability to pay tax. ...

Eastwood & Co. v. MNR, 94 DTC 6411 (BCSC)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege Documents in the nature of simple reports by a conveyance agent relating to certain noted conveyancing matters were not privileged. ...

AFS & Co. Limited Partnership No. 5 v. The Queen, 2001 DTC 5330 (FCTD)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege General discussion of the privilege before finding that specific documents were privileged. ...

In re James Richardson & Sons, Ltd., 82 DTC 6211 (FCA)-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 The issuance of a S.231(3) requirement is not a decision that may be appealed under S.28 of the Federal Court Act. ...

Firestone Tyre & Rubber Co. Ltd. v. Lewellin (1957), 37 TC 111 (HL)-- summary under Agency Summary Under Tax Topics- Income Tax Act- Section 9- Agency- Agency The Court affirmed a finding that sales by the taxpayer, which was a U.K. special-purpose manufacturing subsidiary of a U.S. corporation, were made by it as agent for the U.S. corporation. ...

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC)-- summary under Subsection 152(8) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(8) incorrect year referenced An assessment that erroneously referred to the taxation year of the taxpayers ending on January 2, 1987 rather than December 31, 1986 was deemed to be valid under s. 152(8). ...

Patons & Baldwins Ltd. v. MNR, 69 DTC 189, [1969] Tax A.B.C. 221-- summary under Subsection 147.2(1) Summary Under Tax Topics- Income Tax Act- Section 147.2- Subsection 147.2(1) S.11(1)(g) of the pre-1972 Act was found to preclude the deduction of annual contributions to an unregistered pension plan under the general law relating to deductions by commercial enterprises. ...