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Agence du revenu du Québec, 2025 QCCQ 1127-- summary under Subsection 45(1) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1) the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use In 1981, the taxpayers (10 individuals), acquired as co-owners two adjoining rental buildings containing a total of 82 apartments, with their respective undivided interests in such properties ranging from 2.27% to 29.2%. ...

Indeed … Gilbert v. Agence du revenu du Québec, 2018 QCCA 1792 para. 23 …recognized that through the adoption of this provision, the legislator's intention to prevent the misappropriation of taxes and source deductions by corporate directors is evident. ...

. … Those claims should not, however, prejudice his rights. In other words, exception (a) must be interpreted as being limited to claims that could be accepted and could lead to double refund, and thus only to those submitted within the two-year period prescribed by statute. ...

. … [T]he fact that Chapter 2 was introduced partly for the purpose of forestalling tax avoidance schemes self-evidently makes it difficult to attribute to Parliament an intention that it should apply to schemes which were carefully crafted to fall within its scope, purely for the purpose of tax avoidance. ...

Ss. 26(1) and (2) provided that the amount of allowable input tax is that which is “attributable to” taxable “supplies … made or to be made by the taxable person in the course or furtherance of his business.” ...

It is the place that Courts of Appeals have called the corporation's 'nerve center' … and not simply an office where the corporation holds its board meetings….” ...

Lagotte Succession, 2017 QCCS 330 (Quebec Superior Court)-- summary under Subsection 70(6.2) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6.2) executor was authorized under will to choose not to elect Under the will of his deceased wife, the plaintiff (Picard) was a legatee by particular title of her principal residence as well as of an apartment building on which there was a substantial accrued gain – but was not one of the residuary beneficiaries under her will. ...

Fournier JCQ found (at paras 62, 66, 73-76, TaxInterpretations translation): The RCA proceeds paid to Teitelbaum in 2010 were … a right or property that was part of the estate of Lewin at the time of his death and for which the executors of the estate should have taken possession from its commencement…. ...

. … [T]he Notes… are investments by SLT in debt instruments of BNSIL and TDII, which are non-resident entities. ...

It does not embrace a share that, in the event of a reduction or redemption of capital, does not give its holder the right to participate in the corporation's assets …. ...