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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 In a property tax dispute, counsel moved to couple the taxpayer's appeal with a rectification application, so that the rectification would serve as an alternative if the main appeal failed. ...

The Queen, 96 DTC 1232 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Archambault TCJ. accepted the evidence of the taxpayer's expert witness that the development by the taxpayer of a program improved an existing computer process (enabling the taxpayer to produce more efficient high-quality software products) and was the result of systematic investigation (notwithstanding very little documentary evidence of such investigation). ...

MNR, 93 DTC 5295 (FCA)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment when cheque accepted as payment Interest owing to the taxpayer as a result of the acceptance by his co-shareholders of his offer to sell his shares in a corporation, was found to be received by him at the end of 1990, when he accepted the related cheque as payment (as evidenced by his deposit of the cheque at a branch of his bank that, unlike his local branch, was open that day), rather than early in 1991 when the amount was credited by the bank to his account at the local branch. ...

Brodie & Anor, [1998] BTC 141 (Ch. D)-- summary under Provincial Law Summary Under Tax Topics- Statutory Interpretation- Provincial Law Before rejecting a submission by the Inspector of Taxes that the position of the taxpayers, as members of a Scottish partnership, should be the same as if they were members of an English partnership, Park J. stated (at p. 154) that: "... ...

C.R. 272 (Ex Ct)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt note issued evidencing payment obligation Dividends on preference shares of a corporation, including those held by the taxpayer, were substantially in arrears. ...

., File No. 500-17-125795-230 (Quebec Superior Court)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission annulment ordered of two donations The plaintiff (the Foundation) received two donations, each of $70,000, from the defendant (Millenium) in July 2016 and July 2017. ...

(Canada), 2015 DTC 5067 [at at 5904], 2015 ABQB 327-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission requested rectification order to fix bump did not match parties' specific plan at closing The Bump Mistake A predecessor in interest of the applicant ("Viking") entered a multi-step acquisition and restructuring transaction to acquire an arm's length corporation ("Krang"). ... Dario J dismissed the taxpayer's application, stating (at paras. 77, 81 and 82): [T]his is not a case of the parties "wrote it down wrong", but rather the parties got it wrong. … To the extent we are talking only about the increased bump room due to the Krang Debt, the evidence does not establish that the inability to benefit from this tax treatment would have terminated the acquisition, or that the common intent of the parties that drove them to the formation of the transaction was frustrated. … The intent to complete a transaction in the most tax efficient manner possible is not sufficiently specific. ...

The Commissioner of Income Tax & Anr., Civil Appeal Nos. 8733-8734 of 2018, 2 March 202, Supreme Court of India-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 consideration for software paid by Indian resellers was not royalties for Canadian (and other) Treaty purposes At issue were numerous joined appeals involving the application of withholding tax by the Commissioner of consideration paid by residents of India to non-residents under four broad categories of licensing and sale transactions described below and involving the application of 18 income tax conventions (listed at para. 40, and described at para. 41 as being relevantly “substantially similar”) including that with Canada: Category 1: Computer software purchased directly by an end-user, resident in India, from a foreign, non-resident supplier or manufacturer (for example, a non-exclusive licence to use Samsung software on the end-user’s Samsung mobile device, with a prohibition against making the software available to any other person, or copying it other than for backup purposes). ... Nariman J noted (at paras. 47, 52): In all these cases … no vestige of copyright is at all transferred, either to the distributor or to the end-user. … What is “licensed” by the foreign, non-resident supplier to the distributor and resold to the resident end-user, or directly supplied to the resident end-user, is in fact the sale of a physical object which contains an embedded computer programme, and is therefore, a sale of goods. ... This would be the case regardless of whether the copies being distributed are delivered on tangible media or are distributed electronically (without the distributor having the right to reproduce the software) …. ...

.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no payment on capitalization of interest The taxpayer, who held bonds on which the payment of interest had been suspended, exchanged his matured interest coupons on the bond for interest-bearing 20-year funding bonds of the debtor. ...

.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt issuance of debt certificates not payment An American corporation passed a resolution providing "'that a distribution of seven per cent on the capital stock of this corporation, amounting to $52,500 dollars, be and the same is hereby declared, payable on the 15th December, 1936'" and went on to provide that the distribution should not be payable in cash, but in the form of certificates of indebtedness bearing interest at 4%, and payable approximately four years later. ...