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Canada, 2018 FCA 74-- summary under Tax Benefit Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(1)- Tax Benefit tax benefit to trust from tax-free dividend even though not distributed to a beneficiary In order to strip surplus of an operating corporation (“Gennium”) controlled by the Pilon family, a dividend paid by Gennium was distributed through a series of transactions to a corporation with no assets (“9163”), which then paid the amount to a Pilon family trust (“Satoma Trust” – which also had a corporate beneficiary) as a dividend on special shares that Satoma Trust held in 9163. ...

However, TSI filed a Notice of Discontinuance on May 2, 2016 and the appeal was deemed to be dismissed on June 24, 2016 pursuant to s. 16.2(2) of the Tax Court of Canada Act (the “ TCC Act”). ...

The Queen, 2018 TCC 83-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) two individuals jointly controlling a company were acting in concert respecting the payment of dividends A company (“PES,” or the “Operating Company”) providing electricians’ services initially was owned on a 50-50 basis by two individuals – Smith and Scott, who each was an officer and director, and with Smith overseeing the work at various sites and with Scott responsible for most financial matters. ...

. … Visa acts as a financial intermediary by facilitating the transfer of payments between issuers, acquirers and merchants. ...

. $19M in fees paid to a French lobbyist firm, whose purpose “was to facilitate the implementation of the Pechiney transaction by heading off possible political and public relations issues which might derail the transaction, given Pechiney’s special status … in France” (para. 29), fell into the implementation cost category, and were capital expenditures. ...

He was aware of the hedging effect which the Forward Contract would have on the BNS shares …. ...

. … She registered for the summer semester and paid a single fee. All courses were taken consecutively or “one after the other”, over a ten week semester. ...

., address for invoicing and of electricity use, late payment identification and telephone number) for all its commercial customers who were charged the regular electricity rate – so that CRA could compare this information with what it had in its own files. ...

Its jurisdiction does not extend to judicial review of decisions of the Minister under discretionary relief provisions of the Act …. ...

Graham J accepted the submission of the applicants (the designated partners of the partnerships) in connection with a Rule 58 determination that the Minister could not issue a valid Notice of Determination if the Minister had concluded that the partnership in question did not exist – so that the Notices of Determination were invalid. ...