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Canada, 2012 DTC 5031 [at at 6682], 2011 FCA 355-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer, a producer of plastic containers, undertook a project to "improve the existing product to make it a smaller and significantly lighter storage system" (para. 9 of Statement of Appeal, quoted at para. 5). ... This recognition that thermoforming and injection moulding techniques and procedures were pre-existing (and therefore accessible to other professionals in the field), coupled with the fact that Jentel had previously used both methods and did not suddenly begin to use them in the 2005 fiscal year, supports the reasonableness of the judge's conclusion that Jentel was using an available, standard manufacturing process. ...

Canada, 2017 FCA 39-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission foreign rectification order not dispositive The taxpayer’s Barbados and Cyprus subsidiaries paid amounts to the taxpayer in 2004, 2005 and 2006 as dividends and then, following CRA proposals to assess the dividends, obtained rectification orders from the applicable Barbados and Cyprus courts declaring that the amounts instead were loans to it (or otherwise gave rise to indebtedness). ... Moreover, since these foreign orders involve the appellant and its Foreign Affiliates and not the Minister, a third-party to the foreign proceedings, there is nothing to enforce against the Minister; homologation is therefore a non-issue. … However, Boivin JA further stated (at paras 19-20): I cannot agree … that pursuant to article 2822 C.c.Q. these foreign orders are dispositive and that the Minister has no choice under the ITA but to accept the dividends are actually loans because the orders from Barbados and Cyprus say so. ... These determinations are for the Tax Court judge to make, with a full evidentiary record at his or her disposal. … On this basis, he concluded that Lamarre ACJ should not have answered the Rule 58 question, and set aside her judgment and dismissed the Rule 58 motion before the Tax Court. ...

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. ...

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. ...

His practice income increased dramatically from his 2005 to 2006 fiscal year, and fell again for 2007. Accordingly, his taxable income for his 2006 taxation year was "extremely high relative to the actual income earned for any 12 month period" (para. 11), as he had an addition of 11/12 of his income for fiscal 2006 and a deduction of 11/12 of the much lower income for fiscal 2005. In rejecting a submission that this represented a harsh result, Woods J noted that the effect reversed in the following year – and in any event "it is well established that this Court cannot grant relief on grounds only that the result is harsh: Lans v The Queen, 2011 FCA 290. ...

The taxable income of the affiliate for 2000 had arisen as a result of a 2005 settlement which had reduced a 2001 non-capital loss (and, thus, reduced the loss carryback to 2000), thereby leaving 2000 unsheltered. ... Noël C.J. also agreed with the Tax Court’s rejection of the taxpayer’s submission that given that the word “pour” used in the French version of s. 160(1)(e)(ii) was narrower than “in respect of” used in the English version, s. 160 did not extend to interest that had accrued on the tax payable by the affiliate subsequent to the 2003 transfer date, stating (at paras. 46-47): The phrase “in respect of” is broad and all encompassing … and the word “pour” in the French text can have a similarly broad meaning. … It can be seen that both texts can be read so as to capture interest that accrues on the transferor’s liability from the year of the transfer onwards. This aligns with the purpose of subsection 160(1) which is to allow for the collection of “the total of all amounts” that the transferor is liable to pay under the Act without any distinction as to the makeup of these amounts … and without any time limitation. … Words and Phrases in respect of ...

Canada (National Revenue), 2020 FCA 32-- summary under Subsection 18.1(3) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18.1- Subsection 18.1(3) a CRA proposal letter is not a judicially-reviewable decision or order Two weeks after the completion of an audit and being informed of proposed reassessments for his 2005 to 2014 taxation years, the taxpayer filed an application under the voluntary disclosure program (VDP). ... In confirming the decision of the Federal Court to the same effect, Rennie JA stated (at para. 21): The [latter] proposal letter … is not a reviewable decision or order. … [I]t did not determine any of the taxpayer’s rights, substantive or procedural…. Before so concluding, he stated (at paras 13, 17): The Notices of Reassessment having been issued, the question whether an injunction could have issued restraining their issuance pending determination of the second-level VDP application is moot. … [T]he reassessments are valid and binding until set aside by the Tax Court…. ...

Canada, 2018 FCA 163-- 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) bad debt claim requires the specific identification of which “debt” claims went bad Partly as a delayed consequence of CRA’s seizure of computers and dental equipment of a dental practice and the misplacing of records when his practice subsequently was closed, the dentist was only able to collect a portion of the revenues that he had included in his 2005 to 2008 returns. ... In agreeing with this finding, and before going on to find that there was no reversible error, Boivin JA stated (at para. 5): [T]he Appellant did not provide particulars regarding who his debtors were or how much they owed. … [I]n order to have a “liquidated money demand, recoverable by action” one must know the identity of the debtor and the amount owed …. ...

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] …. ...

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. ...