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As Justice Rand wrote, “[t]he capital machinery within and by means of which the business earning the income is carried on is distinct from that business itself” (Tip Top Tailors …). ...

The Queen, 2022 TCC 13-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) s. 104(6) permitted the deduction of an amount initially treated as a capital distribution An estate engaged in accelerated pipeline transactions in which it transferred shares (stepped up under s. 70(5)) of a portfolio company (“Holdco”) to a Newco in consideration for a note, with Holdco being wound up into Newco a day later – and with the note being repaid by Newco to the estate about three weeks later. ...

(r.4) and (r.5), and further stated (at para. 67): The judgment … rendered [in the 2009 Decision] now hangs by a thread because of the new financial services definition. ...

It may well be the case … that the error in the tax remittances was not made by the CRA or alternatively …that the Applicants could have filed the NR Returns before the filing deadline. ...

. … A reasonable person in the same circumstances as Mr. Procopoudis may well have concluded that the position of the Appellant was clear-cut, that the position of the CRA auditor was incorrect and that professional advice was not required. ...

. … [G]iven that the appellant did not acquire the services, it could not provide them as in kind benefits. ...

. … Words and Phrases income from property ...

" [emphasis added] … Similarly, according to the OECD Model Commentary on Article 23, the use of the phrase "may be taxed" in a Contracting State in an Article of a tax treaty does not confer an exclusive right on that Contracting State to tax income, unlike the phrase "may be taxed only" in a Contracting State (paras. 6 and 7). ...

However, the taxpayer (a Canadian resident with a French rental property), like others, was granted transitional relief so that in 2019 he received a tax credit from the French government equal to the French tax otherwise payable by him on his 2018 income – so that in 2019 he only had to pay the current tax on his 2019 rental income. ...

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