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Structures GB Ltée, 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission corporate reorganization documents could not be rectified to correct for an unforeseen Pt. ... (Canada), so that the rectification order was reversed, the Court stated (at paras. 25, 29-30, 36, TaxInterpretations translation): If the agreement is consistent with what the parties agreed to but simply produces unforeseen tax consequences, due to an error by the tax planners in the design of the tax planning, rectification cannot be granted. … The parties had not planned any specific entitlement [“prestation”] aimed at ensuring that Structures and the holding companies were connected throughout the 31 stages of the corporate reorganization of Structures. … … Mr. Côté, the tax specialist who conceptualized the reorganization, … affirmed that maintaining connectedness was not the object of the transaction, which was to crystallize as much CGD as possible.... ...

Canada (Attorney General), 2025 ONCA 65-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission capital dividends were agreed to be paid in amounts that overlooked a CDA deficit: no rectification A plan was implemented for successive capital dividends to be paid up a chain of corporations so that the individual who was the ultimate shareholder could have a tax-free receipt of $1.4 million. ... …The corporate resolutions that were signed … accurately reflect the agreement. ...

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"). ...

Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business deer-hunting activity was a business based on the taxpayer's subjective intention of generating a profit Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade … or undertaking, or any other income earning activity, carried on with a view to profit. ...

Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit whether an activity qualifies as “carried on with a view to profit" turns on the taxpayer’s subjective intention Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade, profession, vocation or occupation, manufacture or undertaking, or any other income earning activity, carried on with a view to profit. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2-- summary under Separate Existence Summary Under Tax Topics- General Concepts- Separate Existence tax code rests on separate existence of each corporation In connection with finding that a right to work an oil field of a UK subsidiary of a Canadian corporation was not a right of the Canadian corporation to work the field, Lady Rose stated (at para. 88): The idea that an "artificial creation of the legislature", namely a company, has a separate legal personality from its shareholders has been protected and reaffirmed from Salomon v A Salomon & Co Ltd [1897] AC 22 onwards. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 an oil and gas royalty was too remote from a land interest in the oil field to be immovable property under the Canada-U.K. ... Sulpetro has the latter but not the former. … The idea that … a company, has a separate legal personality from its shareholders has been protected and reaffirmed from Salomon v A Salomon & Co Ltd [1897] AC 22 onwards. ...

ARQ, 2025 QCCQ 1330-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA The ARQ assessed the taxpayer within two years of the taxpayer’s dissolution pursuant to s. 210(3) of the CBCA. ...

Agence du revenu du Québec, 2025 QCCQ 378-- summary under Class 29 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 29 contract with detailed specs for provision of concrete, produced by a portable facility at the site of dam construction, was a contract of sale rather than of service The taxpayer (“EMF”), which was a construction company engaged in large civil engineering projects such as roads, bridges and natural gas networks, contracted with Hydro-Quebec (“HQ”) for the furnishing, installation and operation of an on-site portable concrete-producing facility for the provision of the concrete in the installation of a large hydro-electric dam at a remote location. In finding that such a contract should be characterized for as the manufacturing of goods (the concrete) for sale, rather than as a contract of service, Trudel JCQ stated (at paras. 48, 59, TaxInterpretations translation): [T]he evidence shows that the true intention of the parties to the contract was more to ensure, in the construction of the dam, that HQ could obtain supplies of concrete-cement for the purposes of its project to construct “La Romaine 3” power station at all times and continuously, taking into account the challenges linked to the unique conditions of this project. … The Court cannot consider the control measures and contractual requirements of the client as intrinsic characteristics of a service contract, but must rather considers them as representative of HQ's desire to ensure that its supplier would be able to manufacture in sufficient quantity and supply it with concrete-cement in time and place, taking into account the remoteness of its construction site and the extreme geographical and meteorological conditions of a normal construction site. ...

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%. ...