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31 March 2022- 10:41pm Tiessen Interior Design – Federal Court of Appeal confirms s. 256(2.1)’s application to stop a professional firm multiplying the small business deduction Email this Content An incorporated firm of architects and interior designers restructured, so that their practice was now carried on by a partnership between “Partnercos” owned by each of them. ...

14 June 2022- 11:50pm Lubavitch Foundation – Federal Court of Appeal finds that there is no reasonable apprehension of bias where an appeals officer only had minor involvement in a prior taxpayer audit Email this Content The principal argument of a charitable organization in challenging the proposed revocation of its registration was that there was a reasonable apprehension of bias arising from the involvement of Mr. ...

12 July 2022- 10:39pm Jackman – Tax Court of Canada finds that the use of corporate yacht for marketing involving socializing did not generate a shareholder benefit Email this Content The individual shareholder of a corporation (“C.A.B.”), that owned a marina on Vancouver Island, used a 36-foot yacht to stay at other marinas and at boat shows, where he would mingle socially with the boaters and promote the use of the C.A.B. marina (as well as operating a promotional booth, when at a boat show). ...

18 August 2022- 11:30pm Libfeld – Tax Court of Canada does not permit a new home purchaser to resile from the vendor’s certification that it was an exempt sale Email this Content Libfeld claimed the $24,000 Ontario new housing rebate on his purchase in 2018 of an unoccupied and sparsely-furnished home. ...

28 September 2022- 11:22pm Zeifmans – Federal Court of Appeal confirms that its earlier TD Bank decision has been overruled (re prior judicial authorization for s. 231.2(1) demands) Email this Content An accounting firm (Zeifmans) unsuccessfully argued before Walker J in the Federal Court that the Minister should have sought prior judicial authorization under s. 231.2(3) of a requirement to provide information (RFI) issued in the course of a CRA audit of three related resident individuals (the “named persons”) who were Zeifmans clients. ...

3 October 2022- 10:40pm Halwachs – Court of Quebec finds that estimates of a taxpayer’s unreported income based on annual changes to his Swiss bank accounts should be translated using year end spot rates Email this Content The ARQ estimated unreported income of the taxpayer for his 2008 to 2010 taxation years from offshore investments based in part on its application of the “indirect variation method” to the bank statements which it had obtained for his Swiss bank accounts. ...

10 October 2022- 11:52pm Colmvest – Tax Court of Canada finds that a minority shareholder could not use the ETA s. 186(1) rule to access ITCs Email this Content Colmvest, which was the 25% shareholder of a corporation (“443307”), incurred legal fees in an arbitration between it and the 75% shareholder (“QF,” which was owned by an individual unrelated to Colmvest’s shareholder) regarding dividend distributions by 443307. ...

7 November 2022- 10:38pm Wallster – Tax Court of Canada finds that the failure of an issuer to comply with CRA’s demand to allocate its over-renunciation of CEE precluded extending the normal reassessment period Email this Content The taxpayer was renounced Canadian exploration expense (CEE) by an issuer (Quattro) that the Minister subsequently determined had substantially overstated the renounced CEE. ...

17 November 2022- 11:17pm Des Groseillers – Supreme Court of Canada finds that s. 7(3)(a) does not override s. 69(1)(b) Email this Content An individual who donated some of his employee stock options on the shares of a public company to arm's length registered charities, claimed the $3M fair market value of the donated options for charitable tax credit purposes, but did not include any portion of the donated options in his income under the equivalent of ITA s. 7(1)(b). ...

14 December 2022- 11:17pm Leonard – Federal Court of Appeal finds that a mortgage securing a loan cannot be treated as a property separate from that loan Email this Content The taxpayer acquired, from a US bank, a mortgage loan of a US debtor who was in default, for a purchase price of around $1.3 million. ...