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Skatteforvaltningen (the Danish Customs and Tax Administration) v Solo Capital Partners LLP & Ors, [2023] UKSC 40-- summary under Revenue Rule Summary Under Tax Topics- Statutory Interpretation- Revenue Rule revenue rule and sovereign authority rule did not apply where the foreign authority was suing to recover stolen money rather than to recover taxes The respondent, which was the Danish Customs and Tax Divisions (“SKAT”) brought claims in an English civil court seeking to recover £1.44 billion which it had paid based on allegedly fraudulent claims for refunds of Danish dividend withholding tax – SKAT alleged that most of the appellants (“Solo Capital”) had fraudulently misrepresented that they, as shareholders of Danish companies, had been subject to withholding at a rate in excess of the Treaty-reduced rate on dividends when, in fact, they never had held any shares in any of the relevant Danish companies. ...

Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business deer-hunting activity was a business based on the taxpayer's subjective intention of generating a profit Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade … or undertaking, or any other income earning activity, carried on with a view to profit. ...

Cassels Brock & Blackwell LLP, 2013 ONCA 165, rev'g 2012 DTC 5013 [at 6604], 2011 ONSC 6724-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault potential problem did not engage limitations period The plaintiff, along with about 900 other taxpayers, indirectly acquired rights to timeshare weeks at a Carribean resort, and donated the rights to a Canadian athletic association along with enough cash to discharge encumbrances on the timeshare weeks. ... The limitations period could not commence until the claim was discoverable, and a mere " potential problem" does not make a claim discoverable. ...

Revenue Commissioners v Susquehanna International Group Ltd & ors, [2025] IECA 123-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a US LLC was not a resident of the US for purposes of the US-Ireland treaty The taxpayers were Irish resident companies, which were part of a group whose ultimate parent was a single member LLC (“SIH LLC”), which was fiscally transparent for U.S. tax purposes. ... " Allen JA stated (at para. 42) that, as “the purpose of the treaty is to avoid double taxation … it stands to reason that it should only apply to persons who otherwise would be exposed to a liability to pay tax. ...

Eastwood & Co. v. MNR, 94 DTC 6411 (BCSC)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege Documents in the nature of simple reports by a conveyance agent relating to certain noted conveyancing matters were not privileged. ...

AFS & Co. Limited Partnership No. 5 v. The Queen, 2001 DTC 5330 (FCTD)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege General discussion of the privilege before finding that specific documents were privileged. ...

In re James Richardson & Sons, Ltd., 82 DTC 6211 (FCA)-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 The issuance of a S.231(3) requirement is not a decision that may be appealed under S.28 of the Federal Court Act. ...

Firestone Tyre & Rubber Co. Ltd. v. Lewellin (1957), 37 TC 111 (HL)-- summary under Agency Summary Under Tax Topics- Income Tax Act- Section 9- Agency- Agency The Court affirmed a finding that sales by the taxpayer, which was a U.K. special-purpose manufacturing subsidiary of a U.S. corporation, were made by it as agent for the U.S. corporation. ...

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC)-- summary under Subsection 152(8) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(8) incorrect year referenced An assessment that erroneously referred to the taxation year of the taxpayers ending on January 2, 1987 rather than December 31, 1986 was deemed to be valid under s. 152(8). ...

Patons & Baldwins Ltd. v. MNR, 69 DTC 189, [1969] Tax A.B.C. 221-- summary under Subsection 147.2(1) Summary Under Tax Topics- Income Tax Act- Section 147.2- Subsection 147.2(1) S.11(1)(g) of the pre-1972 Act was found to preclude the deduction of annual contributions to an unregistered pension plan under the general law relating to deductions by commercial enterprises. ...