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Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) subsequently discovered bad debts not claimable; unbilled disbursements deductible under s. 9 A review of a law firm's accounts in 2005 revealed that accounts had been rendered in 2002, 2003 and 2004 which were uncollectible and which had not been written off. ...

In 2005, K&D determined that the total amount booked as interest receivable of $495,083 on the loan would not be received and as such it was written-off as a bad debt. ... On a CRA audit in 2009, a copy of the loan agreement was obtained by K & D from Uruguay, and it was determined that the loan was non-interest-bearing. K & D now argued that its deduction of an amount equal to the amounts it had previously recognized as interest income was authorized under s. 20(21). ...

The Queen, 2019 TCC 6-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission a rectification judgment was “justifiably obtained” and, therefore, followed for tax purposes On April 15, 2002, the taxpayer signed an agreement for the purchase of shares of a real estate corporation (“Quatre Saisons”) that stated that the purchase price was to be satisfied by the payment to the vendor (“Placeval,” a corporation owned by a Mr. ... Before granting the taxpayer’s appeal from the assessment, Favreau J stated (at paras. 55, 59-60, 62): [T]he judgment of the Superior Court is not binding on the respondent as neither the Attorney General of Canada nor the Minister was involved in the application. … Although the judgment of the Superior Court is not binding on the respondent and is not res judicata, the conduct of the parties, both before and after the concluding of the transaction, clearly demonstrates their true intention to purchase and sell the shares of Quatre Saisons for nominal consideration and not for consideration based on the future sales of lots. ... The financial statements of Quatre Saisons for its fiscal years ending on March 31 of 2003, 2004 and 2005, also reflected the commissions paid in the cost of the sales of the lots. … [I]t is evident that the agreement, as reduced to writing, contained drafting errors of material importance …. ...

R & S Industries Inc. v. Canada (National Revenue), 2016 FC 275-- summary under Subsection 18.1(2) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18.1- Subsection 18.1(2) extension not granted due to unexplained lengthy delay and lack of substantive merit On September 1, 2005, the appellant (“R & S”) transferred its assets to a limited partnership (“BELP”) which was controlled by its controlling shareholder. ... On November 12, 2010 R & S filed a Notice of Objection asserting that a reassessment of its return for the taxation year of the transfer was based on amounts mistakenly provided on the previously-filed s. 97(2) election form. ... On August 8, 2014, CRA confirmed the reassessment, to which R & S filed a Notice of Objection. ...

" In making its “with a view to profit” determination, the Court noted that the following principles generally were common ground: [S]haring profits … [is] not an essential characteristic of a partnership [citing Young v. ... It follows that the complex mosaic of generally accepted accounting practice … will generally have little part to play. Fourth … the view to profit need not be the predominant subjective purpose, but it must be part of the partners' subjective purpose. ...

Nash, 2005 DTC 5696, 2005 FCA 386-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other purchase price of prints established their FMV as contrasted to speculative retail value A company ("CVI") operated a program through which it sold groups of limited edition prints to individuals, arranged for appraisal and located registered charities to whom the prints could be donated on behalf of the individuals. ... Rothstein J.A. stated (at pp. 19-20, 24-25): It is wrong to assume … that the fair market value of a group of items is necessarily the aggregate of the price that could be obtained for individual items in the group. … For example, if items are sold in large volumes in a wholesale market, the fair market value of the volumes sold in that market will be less than the aggregate of the values of the items considered individually that make up those volumes. … When a court is required to determine the fair market value of an asset for which there is no market that permits a direct comparison, it may be necessary to consider the transactions in some other market, subject to such adjustments as may be appropriate to the case, such as a blockage or volume discount. ...

The Queen, 2005 DTC 384, 2005 TCC 167 (Informal Procedure)-- summary under Subsection 18(12) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(12) In finding that the principal place of business for the taxpayers, who carried on through a partnership a fishing business using two boats owned by them, was the work space in their home, Miller J. stated (at pp. 386-387): "... ...

The Queen, 2005 TCC 693-- summary under Paragraph 28(1)(b) Summary Under Tax Topics- Income Tax Act- Section 28- Subsection 28(1)- Paragraph 28(1)(b) winemaking an integral part of viticulture operation The Minister disallowed the taxpayer’s election to use the cash method on the basis that it did not have a farming business but instead was operating a winery with an attached vineyard and was therefore engaged in the business of making and selling wine. In finding that the taxpayer’s winemaking was linked to viticulture and was an integral part of its farming business, Campbell J stated (at paras. 24-26): It is… one of only a few licensed estate wineries, making wine exclusively from the grapes it grows. … If in any year unfavourable weather conditions or pests adversely affect the grapes grown in the vineyard, it will directly affect the amount and type of wine that may be produced and hence the profit is directly dependent upon the grape growing activities. The winemaking is so directly tied to the activities in the vineyard that the Appellant cannot go to outside parties to purchase grapes because it produces "estate bottled wine". … It is in the vineyard where most of the employees are hired, where most of the equipment is required and used, where the labour expenses are the highest, and where the majority of the acreage is used. ...

The Queen, 2005 TCC 693-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) viticulture and estate winery one business In finding that the taxpayer’s winemaking was linked to viticulture and was an integral part of its (estate winery) farming business, Campbell J stated (at paras. 25-26): The winemaking is so directly tied to the activities in the vineyard that the Appellant cannot go to outside parties to purchase grapes because it produces "estate bottled wine". … It is in the vineyard where most of the employees are hired, where most of the equipment is required and used, where the labour expenses are the highest, and where the majority of the acreage is used. ...

SCDA (2005) Inc. v. Canada, 2017 FCA 177-- summary under Subsection 147(3) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 147- Subsection 147(3) a settlement offer without an element of current monetary compromise can be reasonable Webb JA dismissed the taxpayer’s appeal with respect to an enhanced costs award made by the Tax Court, stating (at paras 29 and 30): One of the Rule 147(3) factors is “any offer of settlement made in writing” (Rule 147(3)(d)). ... University Hospitals Board, 2006 ABCA 101, 384 A.R. 23, the majority of the Alberta Court of Appeal stated that: … Where a settlement offer does not contain an element of compromise, the court may nevertheless consider it to have been reasonable in the circumstances and exercise its discretion to award enhanced costs. ...