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24 November 2019- 11:55pm Holland – Federal Court finds that a taxpayer could not challenge a CRA residency determination that had not yet been assessed Email this Content The taxpayer, who left Canada in 2004 and returned in January 2010, filed a voluntary disclosure application in July 2015 covering the period from 2004 to 2014, but did not file returns for 2005 to 2009, taking the position that for those years he was a non-resident. ...

18 December 2019- 12:16am Stover – Federal Court requires CRA to think about waiving interest that accrued during a three-year delay in dealing with a late-filed Objection Email this Content The taxpayer, who had not filed a Notice of Objection within the normal 90-day period for doing so, filed his Notice of Objection barely within the one-year period under s. 166.1(7)(a) for applying to the Minister for an extension of that deadline. ...

15 January 2020- 12:30am Robitaille – Tax Court of Canada finds that a fully-unintended TFSA overcontribution generated over-contribution tax Email this Content The taxpayer, as a result of tapping the wrong icon on an ATM machine, inadvertently deposited $40,000 to his TFSA rather than his chequing account. ...

5 April 2020- 11:34pm Rojoda – High Court of Australia finds that a partner or former partner of a partnership does not have a fixed interest in its assets prior to winding-up Email this Content The application of various ITA provisions turns on the legal character of a partner’s interest in partnership property. ...

26 May 2020- 12:55am Eisbrenner – Federal Court of Appeal finds that the onus of proof rested at all times with the taxpayer Email this Content One of the difficulties of the taxpayers in a charitable gift program for the donation by them of entitlements to pharmaceuticals (acquired in a distant land) to a registered charity is that they had no granular evidence that they had indeed acquired beneficial ownership of the supposedly-donated pharmaceuticals. ...

16 June 2020- 12:40am Greenfield Mining – Court of Quebec implicitly finds that ETA s. 231 trumps s. 232 Email this Content Greenfield sued a junior Quebec mining company (“CRI”) for unpaid fees of around $15 million and, after 30 months of unfruitful legal proceedings and incurring over $1 million in legal fees, settled its action by agreeing to receive $7 million in instalments over a two-year period. ...

16 July 2020- 11:30pm Bishara – Quebec Court of Appeal reverses the Court of Quebec and finds that the taxpayer realized gains on three condo sales in quick succession on capital account Email this Content The taxpayer purchased a condo in April 2008, for him and his girlfriend and two children to live in, sold it a year later to purchase and move into a less cramped condo- but then, due to their separation, purchased in December 2011 a loft for him to live in. ...

20 July 2020- 11:39pm CanLII – Tax Court of Canada finds that law society funding received by CanLII was consideration for taxable supplies of its services Email this Content CanLII was a not-for-profit corporation providing an open-access virtual law library that had all of its operating budget (of around $3 million per annum) funded by its sole member, being the Federation of Law Societies of Canada (Federation), which collected matching fees from 14 Canadian law societies. ...

13 August 2020- 11:37pm Brown – Tax Court of Canada appears to find that wholly-owned corporations that currently could not legally pay dividends were a source of income for s. 20(1)(c) purposes Email this Content Wong J accepted that interest was deducible by an individual on personal lines of credit (mostly secured on one of his two homes) drawn down by him in order to fund construction, and substantial unexpected renovation work, on two prospective rental properties, or to repay loans from family and friends which initially had funded some of this work. ...

18 August 2020- 11:16pm Gestions Cholette – Tax Court of Canada finds that failure to review a return containing an error that should have been detected was carelessness under s. 152(4)(a)(i) Email this Content Due to what Favreau J found to be carelessness of its external accountant, the taxpayer failed to include, in its income, taxable dividends totalling $920,700 received in 2010 from subsidiaries while, at the same time, claiming a s. 112(1) deduction of $920,700 in computing its taxable income, thereby understating its taxable income by that amount. ...