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In September 2002, Veracity acquired a further 30,000 Gaz Metro units. The payment of the directors’ fees before August 31, 2002 (together with allocations on the Gaz Metro units not occurring until after August 31, 2002) ensured that when the taxable capital gain was reported for the August 31, 2002 Quebec taxation year, the Quebec allocation formula allocated 100% of that income to B.C. ... GAAR rule in s. 68.1 of the Income Tax Act (B.C.): the incorporation of Veracity (which “allowed for the absolute avoidance of B.C. tax, not simply a deferral under s. 85” – para. 42); the transfer of the ALI shares to Veracity (in order to implement the Q-Yes plan; and the adoption of the different year ends. ...

Two MAP agreements between the competent authorities resulted: the initial one; and a second approximately a year later that included 2002 (which the USCA had initially treated as being out of time for relief.) ... CRA asserted that the MAP proceedings did not result in binding agreements between Sifto and CRA and, even if they did, they did not fix the arm’s length transfer price – so that CRA was not only authorized, but was required, by the ITA to issue the post-audit reassessments once in possession of the new audit information. ... To suggest that the MAP agreements simply addressed double taxation of Compass ignores the factual context in which the agreements were reached by the Minister and the IRS through their respective representatives. … …[I]n a letter from the USCA to Compass dated January 25, 2011 … the USCA states: … A mutual agreement has been reached regarding the transfer price of the transaction between Compass and...Sifto…. … This correctly recognizes that the adjustments to income allowed by paragraph (1) of Article IX of the Convention are the result of a transfer price and that it is impossible to agree to the adjustments to the Appellant’s income without also agreeing to the implicit transfer price that yields those adjustments. ...

The Queen, 2018 TCC 224-- summary under Paragraph 166.1(7)(a) Summary Under Tax Topics- Income Tax Act- Section 166.1- Subsection 166.1(7)- Paragraph 166.1(7)(a) no extension necessary as reassessments were void due to taxpayer's incapacity An accountant got the taxpayer (Anna – who at that point was mentally failing), months before her death, to file T1 adjustment requests in 2003 for her 1998, 2001 and 2002 taxation years to allocate increased management fees and employment income to her by the family companies. ... Therefore, the notices of reassessments responsive to the 2003 filings … were void. … [T]he reassessments were consequential to invalid or unlawful filings and issued by the Minister under innocent mistake of fact. Accordingly, no objection was required to the void reassessments. … Bocock J went on to vacate those reassessments. ...

In the Markou case, Paris J found (at para. 108) that “ donative intent in civil law, as in common law, is always an essential element of a gift, even a partial gift,” whereas here “there was just one interconnected transaction and no part of it can be considered a gift that was given in expectation of no return” (para. 109). ... In rejecting the proposition that this entailed an implicit recognition that there was “donative intent” for such cash components, Paris J stated (at para. 112): The Consents relate to donations made after December 20, 2002 and to which the split gifting amendments would apply. ...

Frucor Suntory New Zealand Limited v Commissioner of Inland Revenue, [2022] NZSC 113-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) NZ GAAR applied to treat interest coupons under a convertible loan and forward purchase arrangement as mostly principal In January 2002, a New Zealand “Buyco” (DHNZ) in the Danone group had acquired a NZ target company. In March 2003, in connection with the (planned-since-February 2002) refinancing of the 2002 acquisition, Deutsche Bank advanced $204 million (the maximum amount permitted under the NA thin capitalization rules) to DHNZ in exchange for a convertible note redeemable at maturity in five years’ time at Deutsche Bank’s election by the issuance of a specified number of non-voting shares in DHNZ. ... BG1(1) of the Income Tax Act 2004 (NZ) provided that a tax avoidance arrangement (defined to include an arrangement that has “tax avoidance as its purpose or effect … [or] as 1 of its purposes or effects … if the purpose or effect is not merely incidental”) was void as against the Commissioner. ...

Agence du revenu du Québec, 2025 QCCA 745-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) the transformation of 2 floors of commercial building to residential use did not qualify as a “termination” of commercial activity for QST purposes Starting in 2002, St-Joseph incurred costs in converting the 1 st and 2 nd floors of a 12-storey mixed-use tower from commercial rental use into rental seniors’ residences (RSRs). St-Joseph argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ... " In rejecting this position and before dismissing St-Joseph’s appeal, the Court stated (at paras. 4-5): [Its] argument … fails to explain how the transformation aimed at a new activity is, in itself, related to the termination of the previous activity. … [T]he expenses for the renovation and transformation into an RSR were not related to the termination of the commercial rental activity, and the judge's conclusion that they could not be linked to it is free of error. ...

Pamel J referred in numerous places in his reasons for judgment to the “open court” principle, including the statement by the Supreme Court in Sierra Club, 2002 SCC 41, that “ [t]he link between openness in judicial proceedings and freedom of expression has been firmly established by this Court.” ... This means that he controlled the timing of this introduction. … [H]e had the option of asking the Court to make an order to protect any information he wished to keep private and confidential. … [S]ection 318 of the FCR should not be considered in isolation. Faced with a problem such as the one faced by Rémillard, the Court is capable of finding a solution that balances, to the extent possible, the objectives of meaningful review of administrative decisions, procedural fairness, and the protection of any legitimate interest in confidentiality while at the same time maintaining the open court principle …. ...

This was accomplished by those shares being distributed out of the trust to his wife qua capital beneficiary in 2002, followed by their immediate gifting to him. ... Mady must be determined solely by reference to that transaction. … [T]he transfer of the shares from her to Dr. ... Mady. … … [Per] Groupe Honco … “one of the main purposes” … “…implies that a taxpayer may have more than one main motive in acquiring shares”. ...

In April 2002, Aviva had been granted an option, pursuant to the shareholders’ agreement for Gestion Lagarde, to subscribe at any time after May 1, 2005 for such number of common shares of Gestion Lagarde as would result in it holding 66.3% of the class. ... In finding that s. 148 was not breached by the 2002 option, so that it was valid, Rip J stated (at paras. 48, 50): [N]either Aviva nor an assignee "held" or owned shares of Gestion Lagarde or RJCG before April 28, 2006. … Until such time as the contemplated transaction closed, it is arguable that Aviva could have carved up its rights to acquire the shares among other persons so that, at closing, it would acquire not more than 20 per cent of the target company. ... Given the validity of the April 2002 option to acquire the shares of Gestion Lagarde, that option caused such shares to not qualify as those of a Canadian-controlled private corporation, so that during the 24 months preceding the disposition on April 28, 2006 of the RJCG shares, they did not qualify as shares of a qualified small business corporation. ...

Commissioner of Taxation, [2015] FCAFC 154, aff'd [2016] HCA 42-- summary under Subparagraph 115(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(i) no apportionment possible between resident and non-resident services The taxpayer was employed by Glencore International AG (“GI”) or a subsidiary from November 1991 to December 2006, with his employment in Australia commencing in 2002 when he also became an Australian resident. ... [N]o part of the Amount can be accurately characterised as earnings “derived … from … foreign service”, as opposed to earnings derived from foreign and Australian service. … [T]he Amount was incapable of apportionment as between earnings from foreign service, on the one hand, and earnings not from foreign service on the other because the agreed method of calculating that Amount did not allow for that distinction to be made. ...