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11 December 2014- 9:25am Black – Federal Court of Appeal affirms a finding that Treaty residence in the U.K. did not stop CRA from treating Conrad Black as a Canadian resident Email this Content In 2002, Conrad Black was resident in Canada under general principles but was resident in the U.K for Treaty purposes under the tie-breaker rules.  ... The Queen, 2014 DTC 1046 [at 2882], 2014 TCC 12, briefly aff’d 2014 FCA 275, under Treaties – Art. 4, Art. 29, Stat. Interp. – Other/Conflicting Statutes, and  Interp. Act- 45(2). ...

. – Tax Court of Canada denies the deductibility of Saskatchewan potash tax “base payments” on the basis that they were not incurred to produce income Email this Content The taxpayer, which produced and sold potash from mines in Saskatchewan, was subject to both a profit tax and to the making of “base payments” under the Mineral Taxation Act, 1983 (Saskatchewan). In finding that the base payments made in its 1999 to 2002 taxation years did not satisfy the requirement under s. 18(1)(a) of having been incurred for the purpose of producing income from the taxpayer’s business, Owen J applied the principle that since an income tax is imposed on the profits generated by a business rather than being incurred to generate those profits, it cannot satisfy this purpose test. ... The Queen, 2022 TCC 75 under s. 18(1)(a) – income-producing purpose and s. 18(1)(m). ...

7 April 2024- 9:38pm St-Joseph – Court of Quebec finds that the transformation of 2 floors of commercial building to residential use did not qualify as a “cessation” of commercial activity for QST purposes Email this Content 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 residences for rental to seniors. 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 submission, and in confirming the denial of input tax refunds, Lachapelle JCQ stated (at paras. 93, 103, TaxInterpretations translation): [T]he intention of St-Joseph was that the work carried out on the first and second floors of the Building was to adapt the building for residential or lodging use of individuals. … The Court concludes that the concept of the cessation of an activity does not include the transformation of the activity. ...

29 June 2023- 11:28pm Amex Bank – Tax Court of Canada finds that costs of Amex’ points program were inputs to its exempt credit card revenues, and did not generate ITCs Email this Content CRA denied the input tax credit (“ITC”) claims of Amex for its 2002 to 2012 taxation years for GST/HST paid on expenses arising in connection with the administration and operation of Amex’s Membership Rewards Program (“MRP”), including expenses incurred for the purpose of providing its cardholders who were members of the MRP (“Members”) with rewards on the redemption of points earned by them mostly through making purchases on their cards. ...

In 2002, his 1998 return was reassessed to deny his $47 million interest deduction and to increase the reported capital gain arising under s. 128.1(4). ... In June 2006, a similar departure trade case (Grant – subsequently affirmed), denied the interest deduction. ... Near JA affirmed the decision below that the decision of the Minister’s delegate to deny relief of the assessed interest had not been established to be unreasonable, noting that: Telfer … stated that a taxpayer who knowingly fails to pay a tax debt pending a decision in a related case “normally cannot complain that they should not have to pay interest” …. ...

18 February 2021- 11:40pm Paletta – Tax Court of Canada decision supports the offsetting of almost $200M in taxable income through straddle trades Email this Content The taxpayer in Friedberg entered into spread positions in gold futures contracts, and in the same taxation year closed out the losing legs on his straddle positions (while entering into further contracts to maintain his hedged position) but deferred closing out the remaining contracts until the subsequent taxation year. ... In finding that the taxpayer’s claimed losses (except for an $8 million overstatement of the 2002 loss due to an “egregious error” – for which a gross negligence penalty was sustained) were fully deductible, Spiro J noted: “ Friedberg stands for the proposition that straddle traders may report the results of their trades for tax purposes on a [realization] basis that does not reflect the true economic results of such trades.” ... The Queen, 2021 TCC 11 under s. 9 – timing, General Concepts – Sham and s. 163(2). ...

The basement unit, which represented 54% of the triplex, had been occupied by him for use as his residence and a home office since his purchase of the triplex in 2002. ... This decision likely is inconsistent with the CRA view (e.g., in 2011-0417471E5 and 2016-0651791C6 – both referred to by Breault JCQ) that a duplex or triplex is a single property for tax purposes. ... Agence du revenu du Québec, 2019 QCCQ 6708 under s. 54 – principal residence. ...

25 September 2020- 12:07am Godcharles – Court of Quebec finds that a sale of goodwill occurred between parties acting in concert given the role of a dominant player Email this Content A retirement home was co-owned by eight individuals and operated by a corporation of which they were the shareholders. ... Godcharles was the sole director of all aspects of the transaction, from the purchase of the land in 2002 to the sale in 2006, with all the other plaintiffs seemingly absent from the entire negotiation.” ... Agence du revenu du Québec, 2020 QCCQ 2219 under s. 251(1)(c) and General Concepts – fair market value – real estate. ...

30 December 2015- 10:37pm Blank – Australian Full Court finds that phantom units were not taxable when they vested Email this Content In 1994, a non-resident executive was granted units which entitled him, on retirement, to receive payments calculated by reference to the consolidated profits of Glencore International AG, a Swiss corporation. ... The taxpayer also unsuccessfully argued that a pro rata portion of the U.S.$160 million was exempt based on the fact that for roughly his first eight years of service after the grant of the units, he had been a non-resident employed outside Australia, and came to Australia to work for an Australian sub (and became an Australian resident) only in 2002. ...