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25 September 2016- 9:42pm Kvas – Tax Court of Canada finds that ss. 84(2) and 160 cannot apply to an involuntary dissolution Email this Content The general contracting corporation (“CIA”) of two brothers was dissolved for failure to file Ontario corporate tax returns. ...

6 October 2016- 11:19pm 407 ETR – Tax Court of Canada finds that Ontario government charges to the 407 Highway operator for OPP patrol services were for an HST-exempt supply of a “municipal service” Email this Content D’Arcy J noted that since “policing services are one of the core services provided by a municipality,” and since the HST exemption in Sched. ...

12 October 2016- 1:26am Hall – Tax Court of Canada confirms that the assessment of Part I tax returns does not engage the running of statute-barring for taxes under other Parts Email this Content D’Auray J confirmed that a T1-OVP form is technically a return made under a separate part of the Act (Part X.1), so that the assessment of timely filings of regular Part I returns of the taxpayer did not commence the running of the normal reassessment period respecting his required reporting of excess-RRSP contribution tax. ...

4 November 2016- 12:09am Jacques – Tax Court treats a 401(k) plan as a savings plan rather than as a superannuation or pension plan Email this Content Graham J found that a 401(k) plan before him was a savings plan rather than a superannuation or pension fund or plan, so that a payment of the balance in the fund to the Canadian beneficiary was not income in her hands. ...

18 November 2016- 1:45am Cheema – Tax Court of Canada confirms that a bare trustee is transparent for tax purposes Email this Content The availability of the new housing GST/HST rebate to the taxpayer under ETA s.254(2) turned on him (or his spouse) being the only person who was “liable” under the purchase agreement. ...

7 December 2016- 10:52pm Koskocan – Tax Court of Canada finds that an individual signing most of a company’s cheques was not a de facto director (for director liability purposes) Email this Content A taxpayer sold all his shares of a company to his son, resigned as director, but continued to sign most of the cheques due to bank requirements. ...

9 December 2016- 12:18am InterOil – B.C. Court of Appeal invalidates a Plan of Arrangement which had received strong shareholder support Email this Content The Yukon Court of Appeal (composed of members of the B.C. ...

3 January 2017- 10:56pm Arsove – Tax Court of Canada finds that there was no s. 126(1) foreign tax credit for US taxes for which a spurious offsetting U.S. credit had been claimed Email this Content A Canadian-resident individual and U.S. citizen was subject to US. income tax of 15% on a distribution to her out of her IRA. ...

9 January 2017- 11:50pm Meilleur – Tax Court of Canada finds that high-risk and high-yield loans were not made in the course of a money-lending business Email this Content Bocock J found that a retired husband and wife, who used their own retirement funds and their line of credit in 2006 and 2007 to make five loans to two real estate developers at interest rates ranging from 15% to 24%, were not thereby engaged in a money-lending business given inter alia that they made the loans on a pooled basis along with other investors rather than being involved in negotiating and managing the loans. ...

15 January 2017- 11:07pm Reiss – Tax Court of Canada denies ITCs because purchases were evidenced by invoices not issued in the actual supplier’s name Email this Content Lafleur J found that because invoices received by a Quebec taxpayer, corresponding to purchases made by it, were issued in the name of suppliers it had not dealt with, the invoices did not satisfy the ETA documentary requirements, so that its ITC claims were properly denied. ...