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1 April 2024- 9:09am Chad – Federal Court declines to issue a compliance order to the Canadian protector of non-resident trusts who had refused his request for information demanded under s. 231.2 Email this Content Mr. ...

3 April 2024- 11:29pm TD Bank – Federal Court finds that s. 227(4.1) attaches to proceeds of the deemed trust property when paid to an unsecured creditor, which lacks a purchaser for value defence Email this Content TD Bank received all of the net proceeds of the sale of the business of its customer (the “Debtor”) in repayment of the Debtor’s unsecured overdraft with the Bank. ...

17 April 2024- 11:34pm Encore Cellular – Tax Court of Canada finds that a Canadian buyer could not generate ITCs under ETA s. 178.8 on goods bought from non-residents without showing they had borne GST Email this Content The taxpayer claimed that it was entitled to input tax credits (ITCs) pursuant to s. 178.8 respecting cellphone and other goods which it had acquired, for resale in Canada by it, from non-registrant, non-resident suppliers. ...

29 April 2024- 12:16am Madison Pacific – Tax Court of Canada indicates that the taxpayer’s pursuing a no “avoidance transaction” argument should increase its costs Email this Content Madison Pacific (2023 TCC 180) held that there was a GAAR abuse of s. 111(4) when two unrelated companies acted in concert to acquire 46.6% of the voting rights and 92.8% of the taxpayer’s equity (through being issued inter alia Class C non-voting shares) so as to access the taxpayer’s losses. ...

1 July 2024- 10:58pm Iris Technologies – Supreme Court of Canada notes that the Federal Court has jurisdiction over matters of reprehensible CRA conduct (none was alleged here) Email this Content Kasirer J confirmed the decision of the Federal Court of Appeal to strike a Federal Court application of Iris Technologies Inc., which sought a declaration that Iris was denied procedural fairness in the audit and assessment process, that the resulting assessments were made without an evidentiary foundation and that they were issued for the improper purpose of depriving the Federal Court of jurisdiction to hear its administrative law grievances. ...

1 October 2024- 10:52pm Mandic – Tax Court of Canada orders the implementation of a settlement agreement notwithstanding the taxpayer’s death before the final version could be signed Email this Content Mandic reached a form of agreement with the Crown regarding a reassessment of his 2015 taxation year, and the parties signed a consent to judgment stating that the reassessment would be vacated. ...

2 December 2024- 11:06pm Laprairie – Tax Court of Canada finds that a settlement agreement did not trench on the taxpayer’s right to direct how his non-capital loss should be applied Email this Content A group settlement reached in respect of the appeals of a large group of taxpayers including the taxpayer allowed a deduction of losses in a specified amount for their 1995 and 1996 taxation year, allowed interest expense claims for various periods and allowed “any consequential claims by [the taxpayers] for the carryforward or carryback of any losses resulting from the reassessments set forth above.” ...

26 January 2025- 10:48pm Enns – Federal Court of Appeal finds that a widow was not a spouse of her deceased husband Email this Content After the death of her husband, the taxpayer received the proceeds of his RRSP as the designated beneficiary thereof, and transferred those proceeds to her locked-in retirement account. ...

27 January 2025- 11:31pm Madison Pacific – Federal Court of Appeal finds that Deans Knight applied to a corporate restart plan Email this Content Madison Pacific spun out its existing mining assets so that it was a shell with only tax losses, and then the B.C. real estate companies of two individuals transferred various real estate assets, including jointly owned properties, to Madison Pacific and received shares that resulted in them having a combined total of 46.56% of the votes and 92.82% of the equity. ...

1 April 2025- 11:30pm MEGLobal – Tax Court of Canada effectively finds that a taxpayer had no remedy for a refusal of CRA to accept a requested s. 247(10) downward adjustment Email this Content In objections of the taxpayer to reassessments of three of its taxation years to reflect upward transfer pricing adjustments under s. 247(2), it included requested downward adjustments pursuant to s. 247(10). ...