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21 May 2024- 11:47pm Carter – Tax Court of Canada finds that s. 84.1 did not apply to a sale of the taxpayer’s Opco shares to her cousin’s holdco for cash funded by an Opco dividend Email this Content The appellant, her cousin (“McAllister”) and her father held 40%, 40% and 20% of the common shares of Brown’s Paving Ltd. ... “[T]he transactions were structured in the way they were to benefit Corco … [which] needed a way to finance the purchase.” ...

10 November 2024- 11:19pm Auer – Supreme Court of Canada finds that the validity of Regulations is to be determined under the Vavilov reasonableness test Email this Content Various Canadian decisions have reviewed whether the scope of regulations or other subordinate legislation was consistent with the governing tax legislation and, if not, whether it should be struck out or read narrowly to bring the subordinate legislation back into scope. ... Auer, 2024 SCC 36 under Statutory Interpretation – Regulations/ Statutory Delegation. ...

3 August 2021- 7:17am Daville Transport – Tax Court of Canada provides for an apportionment of trans-border supplies of fuel and maintenance services for GST/HST purposes [corrected link] Email this Content The taxpayer (DTI) used its trucks, and independent contractors as drivers (to whom it paid a per-trip fee), to transport freight in Canada and the U.S. ... VII, s. 1(1) – freight transportation service, s. 142(2)(a) and s. 142(2)(g). ...

24 August 2016- 11:00pm Granofsky – Tax Court of Canada finds that a taxpayer’s counsel can consent in writing to reassessment of the taxpayer Email this Content S. 169(3) provides that Minister may at any time reassess, with the consent in writing of “the taxpayer.” ...

24 November 2016- 12:19am Shreedhar – Tax Court of Canada finds that a taxpayer can appeal a nil assessment of tax if it includes some interest Email this Content Boyle J found that the doctrine that a taxpayer cannot appeal a nil assessment does not apply to a notice of assessment which assesses nil tax but also includes interest (in this case, $2.10). ...

25 September 2017- 12:02am Tang – Tax Court of Canada finds that translated documents were admissible as they previously had been identified in the list of documents provided to the Crown Email this Content Chinese-language documents, that the taxpayer had arranged to have translated into English, were admissible in evidence under Rule 89 given that the list of documents previously provided to the Crown had identified that these documents were translations. ...

22 October 2017- 9:51pm Vrantsidis – Tax Court denies an ADHD-based disability tax credit claim Email this Content Favreau J found that the effects of a teenage son’s ADHD were not severe enough to meet the meaning of “markedly restricted” in s. 118.4(1) so as to qualify a parent for the disability tax credit. ...

12 February 2020- 12:00am Patel – Federal Court of Appeal confirms that an appeal can be bifurcated under s. 171(2) Email this Content Nadon JA confirmed that s. 171(2) gave the Tax Court the discretion to bifurcate the issues in an appeal and deal with one of those issues as requested by the parties in a letter to the Tax Court. ...

9 March 2021- 10:36pm 6398316 Canada – Tax Court of Canada finds that achieving greater cost efficiency is generally not SR&ED Email this Content Russell J rejected the taxpayer’s position that working on ways to construct a highly-energy efficient home for the same cost as a regular home was SR&ED, stating: Conceptually there is no technological aspect implicit in the notion of an item costing or priced at ‘x’ rather than ‘y’ dollars. ...

6 December 2016- 1:37am Robinson – Cour du Québec finds that an individual who went to work full-time in Alberta remained resident in Quebec Email this Content A Quebecer who obtained employment in Alberta and stayed at employer-provided lodges at the various Alberta work sites was found to still be residing in Quebec. ...