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MNR, 2014 ONSC 4983-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission clarification that directions to a trustee shareholder were to be made by the mooted CCPC's board rather than a non-resident executive The applicant ("K-Can") was intended to qualify as a Canadian-controlled private corporation. ...

A.G of Canada, 2015 DTC 5128 [at at 6378], 2015 ONSC 281, rev'd 2018 ONCA 562-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification transactions to avoid s. 98(5) rollover contained 2 more transactions than in original plan In order that the applicant ("CLICC") could realize an accrued capital loss on its 99% limited partner interest in a subsidiary limited partnership ("MAM LP") (and following preliminary dividends): On December 7, 2007, MAM LP distributed an asset to CLICC and a wholly-owned subsidiary of CLICC ("CLICC GP") based on their respective 99% and 1% interests. ...

., 2015 ONSC 7189-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission stock option deduction was peripheral to the larger share sale transaction The general partner of an Ontario limited partnership (“Atria”) granted stock options on its Class C shares to 10 Atria executives. ...

Agence du revenu du Québec, 2018 QCCQ 786-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission taxpayer could reverse an assessment for a taxable benefit by subsequently engaging in self-help rectification On August 15, 2007, Mr. ...

Canada (Attorney General), 2022 BCSC 796-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission declaration made by the parties that their contribution was annulled under Dutch law appeared to have retroactive effect The petitioners were a Dutch cooperative (“Heinz Co-op”) and a B.C. unlimited liability company (“KH Canada”) which was the sole member of Heinz Co-op and the subsidiary of a U.S.- resident corporation. ...

., 99 DTC 537, [1999] 3 CTC 2123 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Two projects for the development of a system for recycling sludge or dealing more economically with the disposition of waste chemicals did not evidence a type of uncertainty that could not be removed by standard engineering practice and routine development and, accordingly, did not qualify. ...

The Queen, 2000 DTC 2353 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development McArthur TCJ found (at p. 2360): "What the Appellant did was take existing technology computer hardware and PacRat software, and record personal messages that cannot be understood or tested by anyone else but [its principal]. ...

The Queen, 97 DTC 684, [1997] 1 CTC 2256 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer was found not to be engaged in SR&ED given that the only tests conducted by it in the year in question was testing of devices already on the market that had been designed from technologies developed in the United States. ...

The Queen, 2009 DTC 687, 2009 TCC 190-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer in carrying out work largely under the supervision of a researcher who was not its employee or representative, and in testing the effectiveness of products that had already been commercially developed, did not qualify for deduction as SR&ED. ...

The Queen, 2005 DTC 457, 2004 TCC 341-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Work carried out by the taxpayers to improve the performance of a tactometer represented "routine techniques and standard procedures generally accessible to competent professionals in the field" (p. 461), and did not qualify as SR&ED. ...