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21 April 2017- 1:47am Ike Enterprises – Tax Court of Canada is inclined to consider cereal to be in the cereal aisle Email this Content After finding that the exclusions from zero-rating for basic groceries should be narrowly construed, Smith J found that crystallized ginger (which CRA sampled and found to be sweet) was not excluded as candy or confectionaries, and that some granola qualified as a breakfast cereal notwithstanding that it appeared to CRA to be packaged so as to encourage its use as a snack. ...

11 May 2017- 12:17am AG Shield – Tax Court of Canada allows individual shareholders to allocate all of their non-dividend earnings to SR&ED wages Email this Content The two 50% shareholders of a small business corporation, that followed the proxy method for SR&ED purposes, decided at year end that their draws during the year would be treated as wages to the extent of the number of hours (multiplied by an hourly rate of $30) spent by them on SR&ED, and that the balance of their draws represented dividends. ...

17 May 2017- 12:29am Gaz Métro – Cour du Québec finds that a “mirror debt” arrangement did not result in a legal release of debt for GAAP and capital tax purposes Email this Content Gaz Métro issued debt in the public markets and then on-lent the money on the same terms to a limited partnership of which it was a 70% limited partner, so that it was the limited partnership which serviced the debt through its “mirror” debt. ...

23 May 2017- 11:24pm Vinet – Cour du Québec finds that managerial actions of an individual limited partner were qua officer of the GP, so that he was a limited partner for tax purposes Email this Content An individual, who was the sole limited partner of a Quebec limited partnership (“SEC”) that owned and operated multiple farms, and the president of its general partner, argued that he was not a limited partner under the Quebec equivalent of ITA s. 96(2.4)(a), so that he could deduct his share of a substantial loss of the LP. ...

5 June 2017- 12:24am Bellil – Federal Court of Appeal states that the absence of an intent to defraud is irrelevant to whether an individual has knowingly made a false statement Email this Content An unemployed engineer spent 11 weeks in Tunisia. ...

9 June 2017- 12:07am Satoma Trust – Tax Court of Canada finds that is was abusive to use s. 75(2) as a surplus-stripping tool Email this Content In order to strip surplus of an Opco, Opco (indirectly) paid dividends to Holdco 1, which made a capital contribution of those funds to Holdco 2, which then paid those funds to a family trust (Satoma Trust) as a dividend on special shares that Satoma Trust held in Holdco 2. ...

25 June 2017- 8:50pm Kaul – Tax Court of Canada allows an art appraiser to testify on her opinions formed in doing reports for the promoter Email this Content An art appraiser, who had been retained by the promoter to value and prepare brief appraisal reports on art to be donated in an art donation program, had previously been prohibited from acting as an expert in Tax Court proceedings respecting the fair market value of the donated art since inter alia she was not impartial. ...

6 July 2017- 1:11am Thompson – Tax Court of Canada finds that a failure to keep asking questions constituted carelessness Email this Content In Aridi, Hogan J found that there was no "neglect" in the taxpayer’s reliance on incorrect advice from his accountant (which he had probed before accepting), so that the reassessment at issue was statute-barred. ...

10 July 2017- 12:18am RFC 2012 – UK Supreme Court finds that payments derived from employment services are assessable even where they are agreed to be redirected to a trust with a 3rd-party trustee Email this Content A group of companies, which ran a Glasgow football club, implemented a scheme for their key employees to avoid income tax on their annual bonuses or other compensation. ...

10 July 2017- 12:17am News Australia – Federal Court of Australia finds that interest was “derived” on an accrual basis on a loan where it was a business asset and there was no collection uncertainty Email this Content Australia, whose statute still has a general inclusion of income “derived directly or indirectly from [a] source…during the income year,” has provided some of the jurisprudence on the meaning of “derived.” ...