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Decision summary
R. (Prudential plc & Anor) v. Special Commissioner of Income Tax & Anor, [2013] 2 All ER 309, [2013] UKSC 1 -- summary under Solicitor-Client Privilege
(Prudential plc & Anor) v. Special Commissioner of Income Tax & Anor, [2013] 2 All ER 309, [2013] UKSC 1-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege In dealing with a claim of privilege asserted with respect to tax advice provided by an accounting firm on a tax shelter transaction, Lord Neuberger stated for the 5-2 majority that, although the rationale for legal advice privilege applies as readily to accountants who provide tax advice as to solicitors or barristers doing the same, such privilege should nevertheless be restricted to lawyers. ...
Decision summary
Williams Moving & Storage (B.C.) Ltd. v. Canada (Minister of National Revenue), 2024 BCCA 160 -- summary under Rectification & Rescission
Williams Moving & Storage (B.C.) Ltd. v. Canada (Minister of National Revenue), 2024 BCCA 160-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission bankruptcy proposal which CRA had misinterpreted is corrected pursuant to discretion under the BIA A drafting error (involving an inappropriate duplication of text) in the proposal which was approved by the creditors of an insolvent company (Williams Moving) and by the B.C. ... In finding that the chambers judge had not erred in denying rectification of the written terms of the proposal, Wilcock JA noted (at para. 68) the finding in Fairmont that “rectification requires the parties to show an antecedent agreement with respect to the term or terms for which rectification is sought” and stated (at paras. 69): [I]t is difficult to see how it can be said that the creditors would have understood the Proposal to be anything other than what was presented to them. … There was insufficient evidence of a common understanding amongst the appellant and its creditors on the matter in dispute …. ...
TCC (summary)
Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251 -- summary under Payment & Receipt
Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by direction A Canadian corporation ("C&A") paid two dividends to its Canadian-resident parent ("Holdings"), which distributed the same amounts to its U.S. ...
FCTD (summary)
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA). -- summary under Payment & Receipt
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt presumed application to oldest debt The taxpayer's practice, in determining its allowance for doubtful accounts at the end of its taxation year on November 27, 1082, included having regard to payments made by trade debtors during the three months after that its year end, but treating receipts as going to the oldest receivables first. ...
News of Note post
8 August 2021- 10:57pm Gélinas – Court of Quebec finds that a Montreal site qualified as a special work site for a 3 ½ year project Email this Content The taxpayer, who had purchased a house in Richmond, Quebec in 1999 to reside there with his family, worked for his employer (“GPH”) as a project engineer regarding the construction or expansion of factories. Although normally, on such projects, the client of GPH would pay the accommodation costs of the GPH employees who worked on the project, that was not the case for a project for one of the clients in the Montreal area (about 90 minutes from Richmond), which started in 2014 and lasted for 3 ½ years. ... In finding that these amounts were not includible in the taxpayer’s income pursuant to the Quebec equivalents of ITA ss. 6(6)(a)(i) and (b)(i), Lapierre JCQ stated: [T]he fact that the wife and one of the children of the couple also lived in the Longueuil apartment is not very important …. … Mr. ...
SCC (summary)
Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. Canada (Attorney General); R. v. Fink, 2002 DTC 7267, 2002 SCC 61, [2002] 3 SCR 209 -- summary under Section 8
Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ...
SCC (summary)
Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. Canada (Attorney General); R. v. Fink, 2002 DTC 7267, 2002 SCC 61, [2002] 3 SCR 209 -- summary under Subsection 232(3)
Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ...
20 February 2016- 11:38pm The s. 248(1) – “disposition” – para. (n) exemption for upstream non-resident mergers is narrower than the s. 87(8) rollover Email this Content Where there is a merger of two foreign corporations whose shares are taxable Canadian property (because of an underlying Canadian real estate or resource sub), s. 87(8) may provide rollover treatment – but there still could be a share disposition giving rise to s. 116 filing and withholding requirements unless the para. ... Summaries of Gordon Zittlau, “Corporate Reorganizations Involving Taxable Canadian Property – Foreign Merger Considerations,” International Tax Planning (Federated Press), Vol. XX, No. 3, 2015, p. 1407 under s. 248(1) – “disposition” – para. (n), and s. 87(8). ...
Decision summary
R & C Commrs v Development Securities plc & Ors, [2020] EWCA Civ 1705 -- summary under Subsection 2(1)
David Richards LJ stated (at paras. 111-112): The clear conclusion to which the FTT came … was put by the FTT at [422], "the Jersey directors were acting under what they considered was an 'instruction' or 'order' from the parent". The inevitable conclusion from that finding was … that the decision to enter into the relevant transactions was taken by the parent in the UK, not by the directors in Jersey. They were, of course, concerned to ensure that what they were being instructed to do was lawful. … Likewise, the directors were concerned to ensure that there were no unexpected liabilities for the Jersey companies, such as stamp duty, and to ensure that the documents were in proper order. ...
BCSC decision
In Re Taxation Act and Income Tax Act and >>in Re Assessments of Firestone Tire and >>rubber Company of Canada, Limited., [1940-41] CTC 342
:—The Firestone Tire & Rubber Co., hereinafter referred to as the ‘‘Firestone Company,’’ is a company incorporated under the laws of the Dominion. ... Counsel for the Minister of Finance conceded that under the decision of Grainger & Sons v. ... The casings so withdrawn are shown in ex. 7 under the heading ‘‘ Net Sales. ’ ’ The Monthly Inventory and Sales Report is forwarded by the Distributor to the Firestone Company in duplicate. ...