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The Queen, 2020 TCC 33 (Informal Procedure)-- summary under Paragraph 8(1)(b) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(b) s. 8(1)(b) did not cover legal costs of an action to extend the period of employment The taxpayer worked as a provisional judge for the Montreal Municipal Court up until 2005, and then served as a full-time judge up until 2012, at which time he was forced to resign as he had attained the age of 70 – which meant that he was 23 months short of the requisite years of full-time service required to generate a full pension. ... Clément was instead seeking was the right to hold his office beyond the age of 70 and to be reinstated in his office so that he could accumulate credits for his pension. … Respecting the second ground, she stated (at para. 29): If Mr. ...

In place of the land covered by the exercise of the option to acquire, for which $400,000 was paid to Les Sommets in 2004 and 2005, the latter transferred another piece of land with the agreement of Solstice. ... As author Jacques Deslauriers writes: "Dation in payment has two effects: the extinction of an obligation and the transfer of ownership". … There is no published case law dealing with the tax treatment of a dation in payment, but from the foregoing, the Court concludes that this transaction must receive the same tax treatment as a sale. … The value of the consideration realized as a result of this transaction, i.e., the market value of the land transferred, established at $400,000, is taxable in the hands of Les Sommets as business income, since the transfer of the land it replaced was to occur as a sale in the ordinary course of business. ...

When the policy terminated in September 2005 on the taxpayer’s attaining 70 years, he received $24,909 from the insurer as the ROP benefit, which equaled all the premiums previously paid under the policy. ... In elaborating on this result, Morgan J stated (at paras. 23-24): The Appellant naturally thought of the ROP benefit ($24,909) as a return of non-taxable dollars. … [T]he phrase “return of premium” may be an accurate description of the maximum amount received by the Appellant upon the expiry of the term but it is misleading for the following reason. ... What the insurer paid as a benefit upon the expiry of the term was not, in a business sense or in an income tax sense, any part of the premiums for life insurance. … It was part of the insurer’s earnings. ...

The principal CRA investigator (Keith Kendall) formed the view that the taxpayers had skimmed $1.7 million from the restaurant between 2004 and 2005. ... Kendal and the CRA to gather the evidence, draft the final Information, and essentially, do charge approval. … … Mr. ... Kendal … wrote the Prosecution Report as an advocate not an investigator. ...

The lower relief for the 2014 application was considered by CRA to reflect the application to those applicants of the prohibition, after a 2005 amendment to s. 220(3.1), to going back more than 10 years with interest relief. ... Barrs’ claim for equitable treatment, and it may be open to the Minister to grant him additional relief from interest that had accrued over the period from 2004 onward, to promote equity with the group of taxpayers who had requested relief in 2004. … Mr. ... Given that the independent third-level review officer failed to engage with the request for greater relief in the open years to ensure equitable treatment, his decision must be set aside. … Failure to engage with an important argument advanced by a party will generally render an administrative decision unreasonable [citing Vavilov] …. ...

This KPMG plan, if it worked, had the tax advantage over the base case of permitting the tax-free distribution of the Gennium surplus to the family members by Satoma Trust – but instead, the Gennium dividends were retained in Satoma Trust for reinvestment. ... A more robust variant of the above tax plan (which apparently was not for the situation in which an asset-protection trust (i.e., FFLP) had already been formed) was reviewed by the KPMG GAAR Committee, who concluded that GAAR should not apply if it could be demonstrated that the s. 75(2) trust was put in place for asset-protection (or other non-tax) purposes – but otherwise it was more likely than not that GAAR would apply. ... Pilon informed of the risk of applying the GAAR did not end in 2005. … Timely advice on CRA's new approach could have led to rectification of the structure and minimized both the risk and the extent of an assessment. ...

Lin, [2018] NZCA 38-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Chinese tax spared on Chinese CFC income and attributed under CFC regime to New Zealand shareholder was not “in respect of” income derived by that shareholder from China As a result of having a 30% interest between 2005 and 2009 in four companies which were resident in China, the taxpayer had the active business income of those companies of $4.6 million attributed to her in New Zealand under the New Zealand controlled foreign companies (CFC) regime. ... In the case of New Zealand, double taxation shall be avoided as follows: (a) … Chinese tax paid under the laws of the People’s Republic of China and consistently with this Agreement, whether directly or by deduction, in respect of income derived by a resident of New Zealand from sources in the People’s Republic of China (excluding, in the case of a dividend, tax paid in respect of the profits out of which the dividend is paid) shall be allowed as a credit against New Zealand tax payable in respect of that income; … 3. ... Contrary to the Judge’s view, we are satisfied that art 23(2)(a) requires the tax to have been paid by a New Zealand resident on income derived by him or her in China, not by a third party CFC; that is the essential precondition to a credit in New Zealand. … In our judgment art 23(2)(a) relieves solely against juridical double taxation. ...

The original agreement for GSs was replaced at various junctures, including in 2005 by the “IPPA 2005,” at which time the taxpayer was granted phantom units (Profit Participation Units, or “PPUs”) in GI for calculating his entitlement to the profit participation ultimately payable to him as deferred compensation (styled as “Incentive Profit Participation” or “IPP”) on the surrender of his rights and which were treated in much the same way as GSs (including stapling to an equal numbers of shares in GH). Under the IPPA 2005, his IPP became due 30 days after his termination of employment on December 31, 2006 and was payable in 20 instalments over five years (with interest). ... There was therefore no derivation of income in the 2007 income year when the first two instalments, though due, were merely withheld from payment to the appellant. … The applicant derived the first two instalments as income when, in January 2008, they were paid, with his agreement, to the FTA by GI on his behalf. ...

Canada, 2005 TCC 392, and Parfeniuk v. Canada, [1996] G.S.T.C. 22. The appellant attempted to negotiate with the Minister to work out a payment schedule for the debt, but he failed to provide the Minister with the information required to complete those arrangements. ... A submission of the appellant that he should not be liable for the unremitted GST of the company because the Minister took too long to assess (over 10 years), was rejected as being inconsistent with Addison & Leyen. ...

. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. The Queen, 2005 FCA 263 …at paragraph 4). If the Minister has issued inconsistent assessments, this will lead to inconsistent pleadings, if the taxpayers appeal to the Tax Court of Canada. ...