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Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper -- summary under Section 224.1
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Section 224.1 Summary Under Tax Topics- Income Tax Act- Section 224.1 Limitations on CRA compensation (set-off) rights (p. 13:36) While Revenu Québec followed the decision in DIMS Construction [fn 111: … 2005 SCC 52] with regards to formal bankruptcies, until quite recently it continued to apply the compensation mechanism to use post-insolvency refunds owed to the tax debtor to reduce pre-insolvency debts when the debtor was the subject of an approved proposal under the BIA. ...
Article Summary
Christian Ehlermann, Marla Castelon, "When Does a Dependent Agent Act Habitually?", Tax Notes International, 26 September 2016, p. 1141 -- summary under Article 5
", Tax Notes International, 26 September 2016, p. 1141-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Proposed change in BEPS final action plan to agency PE effectively elevates "habitually" requirement (p. 1142) [A]rticle 5(5) will no longer require the dependent agent to conclude contracts in the principal's name; it will be sufficient that the dependent agent habitually plays the principal role leading to the routine conclusion of contracts without material modification by the enterprise — that is, the principal. ... Regular recurring trips aggregating less than 60 days each year belwo the threshold (p. 1143) In 2005 the German Federal Tax Court (Bundesfinanzhof) issued a decision in a case in which a director of a Portuguese company traveled to Germany eight times in 1995, 10 times in 1996, 13 times in 1997, and 14 times in 1998 [fn 12: Bundesfinanzhof, case no. IR 87/04 (2005).] During each trip, which lasted two to five days, he concluded contracts with clients and contacted actual and prospective clients. ...
Article Summary
Michael H. Lubetsky, "Interest Relief under the Federal and Provincial Regimes", Tax Litigation (Federated Press), Vol. XX, No. 1, 2015, p. 1182 -- summary under Subsection 220(3.1)
. … Maarsman v. Canada (CRA), 2003 FC 1234 … recognized the "absurdity" of assessing interest during years when no taxes were owing and held in the taxpayer's favour on an application for judicial review. ... Slau Limited, 2009 FCA 270 ….] Application to Agreeing Provinces (pp. 1184-5)... ... The third clause of section 94.1 of the TAA – the privative clause – was added in 1996. ...
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Lucie Lamarre ACJ, Isida Ranxi, "Taxpayer Rights and Voluntary Compliance: The Example of the Canadian Judiciary", Tax Notes International, 3 October 2016, p. 61 -- summary under Evidence
. … [T]he appearance of fairness has another aspect — that is, how the proceedings appear to the unrepresented party. ... May 22-24, 2003 (unpublished) as cited in André Gallant, "The Tax Court's Informal Procedure and Self-Represented Litigants: Problems and Solutions" (2005) 53:2 Can Tax J 333 at 359.] ...
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Joyce A. Young, H. Michael Dolson, "Income Tax Consequences of Carrying on an Unrelated Business", Business Vehicles, Volume XV, No. 1, 2012, p. 782, at 783, 784-785 -- summary under Subsection 188.1(1)
[fn. 8: Technical Interpretation 2005-0095001E5, dated February 22, 2005.] ... [fn. 11: CRA Document October 1991-289, dated October 1991 involving 10 residential properties.] … There appears to be some consensus between the Minister and the academic commentators that the carrying on of a business by a trust established for the benefit of a charity does not constitute a business of the charity.… The better view of the law is that the business carried on by a trust is a business of the trustees and not a business of the trust beneficiaries. ...
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Robert Kopstein, Rebecca Levi, "When Should the Courts Allow Reassessments Beyond the Limitation Period", Canadian Tax Journal, (2010) Vol. 58, No. 3, 475-527 -- summary under Subparagraph 152(4)(a)(i)
The Queen, 2005 DTC 144, at paragraph 44 (TCC)] or in circumstances where the particular factual characterization adopted was intended, and was carefully and thoughtfully planned. ... The Queen, 2005 TCC 78. Bondfield was decided under the parallel provision of the Excise Tax Act, RSC 1985, c. ... AG of Canada, 2005 DTC 5683 (FCA)] or the taxpayer would have known had he not chosen to avoid inquiry. ...
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Justice Marshall Rothstein, "An Overview of the Supreme Court of Canada", Bulletin for International Taxation (IBFD), January/February 2016, p. 20. -- summary under Stare Decisis
.-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis Stare decisis usually applies (p. 20) As the Court recently noted: " stare decisis is not a straitjacket that condemns the law to stasis". ... In the 2005 case Canada Trustco Mortgage Co v. Canada, the Supreme Court agreed with the Federal Court of Appeal which, in a prior unrelated case, had adopted the interpretation of the UK House of Lords' decisions in Furniss v. ...