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8 September 2020- 11:10pm Valovic – Tax Court of Canada finds that shareholders’ services were not consideration for dividends received by them for s. 160 purposes Email this Content An electrician and his spouse provided their services as electrician and administrator to their equally-owned corporation, and received dividends and salary. ...

18 October 2020- 11:47pm Sun – Tax Court of Canada finds that there was a supply of a condo directly from the builder to the assignee of the purchase contract for GST new housing rebate purposes Email this Content One of the requirements for the GST (or Ontario HST) new housing rebate is that there be a sale to the purchasing individual by the “builder.” ...

12 May 2021- 11:04pm Kam-Press – Federal Court of Appeal confirms requirement for use of the scientific method in SR&ED Email this Content A taxpayer acknowledged that the work performed by it for which it claimed investment tax credits did not follow the scientific method as described in Northwest Hydraulics, but argued that “there was no reference to ‘scientific method’ in the text of the definition [of SR&ED].” ...

25 May 2021- 11:40pm Logix Data – Tax Court of Canada finds that alleged SR&ED work was routine engineering Email this Content A taxpayer’s SR&ED claims for work on solar shingles installations were denied by Monaghan J on various bases including that the taxpayer did not have enough knowledge of the field to identify whether its work was advancing the state of knowledge, its work addressed routine engineering challenges and its documentation of the supposed SR&ED work was paltry and not prepared contemporaneously with the work. ...

18 July 2021- 10:57pm Mariani – Supreme Court of Ontario orders a new trial regarding claiming wedding expenses as business expenses Email this Content The trial judge convicted the individual accused and the corporation he owned (“MMFL”), of making a false statement and tax evasion in relation to both personal and corporate income tax returns. ...

17 January 2022- 10:47pm Dias – Tax Court of Canada denies ABILs to 2 individuals who lent to their SBCs through their Loanco rather than directly Email this Content The two individual taxpayers made loans to their two start-up retail-business companies (which were small business corporations) through another corporation (“201”) owned by them (which was not an SBC), rather than directly. ...

29 March 2022- 10:40pm Fortier – Federal Court finds a violation of procedural fairness where the taxpayer was not given a chance to respond Email this Content A CRA agent reviewed an individual’s application for CERB benefits, then contracted the individual’s former employer directly, and was told that he had left employment because his contract had reached its termination date, rather than for COVID reasons. ...

8 February 2024- 11:16pm Cassidy – Federal Court reverses CRA’s declining to provide significant interest relief due to its failing to engage with the taxpayer’s financial hardship request Email this Content The taxpayer requested interest relief under s. 220(3.1) primarily based on his inability to pay due to his divorce, the 2008 economic downturn, and the COVID-19 pandemic. ...

25 July 2024- 11:54pm Hill – Tax Court of Canada finds that employment income earned by a band member at a hospital located near the reserve was not exempted Email this Content A status Indian, who lived on a reserve and worked at a hospital a 10 minute drive away (on land just outside the reserve) was not exempted on her employment income. ...

26 January 2025- 10:47pm Vorsteveldt – taxpayers are challenging the CRA administration of the 2/3 CGIR Email this Content Ms. ...