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22 December 2022- 10:14pm Schofield – Tax Court of Canada finds that headhunter fees expended to increase commission employment income were deductible even though not specified in the employment contract Email this Content A broker employed on commission by BMO Nesbit Burns incurred fees to a headhunter firm to identify an associate who could work for her in canvassing clients and sharing her duties. ...

18 January 2023- 10:32pm 9158-9853 Québec – Court of Quebec finds that incurring 90% of construction costs did not equate to “substantial completion” of an apartment building for QST self-supply purposes Email this Content The appellant (“9158”), which had constructed a 14-storey apartment building, took the position that its self-supply of the building occurred in an earlier reporting period, when 90% of the construction costs had been incurred (a reporting period which was now statute-barred), rather than during a subsequent reporting period, which the ARQ had treated as the proper time for self-assessment. ...

9 May 2023- 11:02pm 2405124 Ontario – Tax Court of Canada finds that a s. 244 Requirement applies to funds that the recipient is directed by its controlling shareholder (the tax debtor) to pay to him Email this Content CRA issued a Requirement to Pay to a corporation (240 Ontario) respecting the unpaid tax debt of its sole shareholder (IB), who was also its officer. ...

21 June 2023- 11:05pm Nolinor – Court of Quebec finds that per-flight-hour allowances paid to crew flying to remote locations came within the s. 67.1(2)(d) exception for full deductibility Email this Content Nolinor, which carried on a business of providing charter flights to generally remote locations, e.g., in Nunavut or Gabon, paid its pilots, crew and mechanics allowances of $3 to $5 per flight hour to cover costs of meals and cleaning their uniforms. ...

29 June 2023- 11:28pm Amex Bank – Tax Court of Canada finds that costs of Amex’ points program were inputs to its exempt credit card revenues, and did not generate ITCs Email this Content CRA denied the input tax credit (“ITC”) claims of Amex for its 2002 to 2012 taxation years for GST/HST paid on expenses arising in connection with the administration and operation of Amex’s Membership Rewards Program (“MRP”), including expenses incurred for the purpose of providing its cardholders who were members of the MRP (“Members”) with rewards on the redemption of points earned by them mostly through making purchases on their cards. ...

16 July 2023- 11:40pm Larouche – Court of Quebec determines the relative business use represented by a home office using the home’s gross rather than net area Email this Content In deducting his home office expenses, the taxpayer determined the portion of his home that was used in his business of providing electrical engineering services, which he calculated by dividing the square-foot area of the three rooms that he used in that business by the net square footage of his home, which was the area of the two floors as measured by the exterior dimensions, minus the areas taken up by the walls and minus the area of common areas (stairwells and hallways). ...

31 July 2023- 10:58pm Hydro-Québec – Federal Court of Appeal finds that an s. 231.2 requirement that essentially repeated a requirement previously rejected under s. 231.2(3) was not res judicata Email this Content Hydro-Québec (2018 FC 622) found that an s. 231.2 requirement for information concerning a large grouping of Hydro-Québec customers should not be authorized pursuant to s. 231.2(3) on the grounds inter alia that they did not constitute an “ascertainable group.” ...

1 August 2023- 11:33pm Greer – Tax Court of Canada finds a shareholder benefit regarding a transfer to an individual shown on the register as holding one of the 1000 shares Email this Content Spiro J applied the presumption in s. 181(3) of the Business Corporations Act (NB) that an entry in a share register is, in the absence of evidence to the contrary, proof that the holder shown in the register is the owner of the share, to find that the transfer of four properties (valued by Spiro J at over $2.4 million) by a corporation to the taxpayer, who was shown in the register as holding one of the 1000 shares, gave rise to a corresponding shareholder benefit under s. 15(1). ...

14 August 2023- 11:43pm Azzopardi – Tax Court of Canada finds that a limited partner was bound by the settlement made by the partnership’s designated member Email this Content After the Minister made an initial determination that the losses of a film partnership for its 2001 fiscal period were $134.9 million rather than the claimed amount of $255.8 million, the partner who was the designated member filed a notice of objection on behalf of the partnership, resulting in the Minister redetermining the loss to be $194.9 million. ...

29 August 2023- 11:13pm Thomas – Federal Court allows the provision of new evidence on an application for judicial review Email this Content The taxpayer’s request for waiver of interest and penalties regarding her late filing of T1135 forms, based on the medical situation of her and her husband, was denied (at two levels) on the grounds that such situation did not prevent her from filing those forms on time. ...