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24 August 2020- 11:58pm Banque Laurentienne – Tax Court of Canada finds that fees paid by the issuer of subscription receipts to the investors themselves were deductible under s. 20(1)(e) Email this Content In order to finance an acquisition, Laurentian Bank issued subscription receipts to two private placement investors (the Caisse for $100 million and a labour fund for $20 million) at a subscription price representing a 2% discount to the market trading price, and with the subscription proceeds being held in trust until the closing of the acquisition, at which point, the subscription receipts were converted, without further payment, into common shares of the Bank. ...

18 October 2020- 11:48pm Biya – Tax Court of Canada finds that a taxpayer who worked on a long-time basis in Ethiopia with a home there nonetheless resided in Canada Email this Content The taxpayer came to Canada from Ethiopia in 1981 but, following his separation from his wife, worked in Ethiopia from 2006 to 2015 for Canadian-headquartered companies while maintaining a home with a live-in girlfriend there. ...

5 November 2020- 10:43pm Yorkwest Plumbing – Tax Court of Canada finds that difficulties in allocating costs between Years 1 and 2 could not be solved by deducting them in Year 3 Email this Content In the course of its 2012 taxation year (a “year”), the taxpayer discovered that, as an indirect result of switching over to a new system for accounting for inventory at the beginning of its 2010 year, it had failed to deduct in that and the 2011 year, the $1.3M cost of inventory that it had acquired shortly before its 2010 year. ...

24 November 2020- 11:08pm Ouazana – Tax Court of Canada finds that a retroactive GST registration of a real estate buyer relieved the vendor of liability for failure to charge GST Email this Content In February 2014, the taxpayer made a taxable supply of real property to a purchaser which represented that it was registered for GST and QST purposes but, in fact, was not, so that the registration numbers it provided were invalid. ...

26 November 2020- 10:57pm 1089391 Ontario – Tax Court of Canada denies relief where the taxpayer mistakenly applied for the new housing, rather than new rental property, HST rebate Email this Content The taxpayer, a private company, was credited with the new housing rebate, which was assigned by it to the vendor, on its purchase of a new residential condominium unit, notwithstanding that it purchased the unit only for rental purposes. ...

21 December 2020- 11:08pm Fazal – Tax Court of Canada apparently finds that an individual’s dissolution of a proprietorship terminated her GST/HST registrant status Email this Content An individual carried on a proprietorship, which was registered for GST/HST purposes, and shortly thereafter incorporated that proprietorship, with the corporation receiving a fresh GST/HST registration. ...

11 January 2021- 10:55pm London Clubs – UK Supreme Court finds that gaming profits from bets staked did not include chips and vouchers distributed free of charge for promotional reasons Email this Content It was held that non-negotiable chips and free bet vouchers provided free of charge by casino operators to selected gamblers to encourage them to gamble were not to be included in computing the casinos’ “bankers’ profit” from bets “staked” and, thus, were excluded from gaming duties. ...

16 February 2021- 11:07pm Luxury Home Landscape – CRA fails to establish the mailing date of an assessment due to not having a copy of a Canada Post Certificate of Registration Email this Content The Crown brought a motion to quash the corporate taxpayer’s notice of appeal from a GST/HST notice of confirmation on the grounds that the notice had not been filed within 90 days of the CRA sending, by registered mail, the notice of confirmation. ...

22 February 2021- 10:30pm Bank of Montreal – Tax Court of Canada awards pre-settlement offer legal costs at more than the party and party rate in order to encourage timely settlement offers Email this Content The Crown agreed that BMO was entitled to substantial indemnity costs of $450,069 for the legal costs incurred by BMO after it had made a settlement offer (over seven months before the Tax Court hearing), but argued that BMO was entitled to receive costs only at the meagre Tariff rate for its legals incurred before then. ...

1 March 2021- 11:24pm Goldman – Tax Court of Canada finds that s. 160(1) did not apply to a transfer to an individual qua trustee of a valid oral trust Email this Content The taxpayer was designated as the beneficiary of her mother’s RRSP, but was orally told by her mother that this was occurring on the condition that she was to use those proceeds to pay various bills and estate-related expenses and divide the remainder equally with her two sisters. ...