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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. ...

In December 2005, Canada Inc. purchased land with a view to using it in a condominium project. ... He then stated (at paras. 38-39): Permitting the crystallization of the time for the benefit respecting the transfer of a future immovable to be prior to the time when the property exists is not only impracticable, it is also an impossibility. … …[As per] Robertson and Henley … it is only when the condition or contingency is met that such a benefit arises. ...

Gagné objected on the basis inter alia that he had ceased being a director for more than two years before such reassessment, and a few days before the trial of the appeal of his estate (following his death) from such reassessment, its notice of appeal was amended to allege inter alia that Gagné had never been a director (given that the proper corporate procedures had not been followed for his appointment, including his consenting to such appointment. and there being an absence of any resolution appointing him) – an argument that Gagné. ... Third persons may submit any proof to refute the information contained in a declaration …. and noted that the ARQ had been entitled to rely on the rebuttable presumption arising under s. 62. He also indicated (at paras. 44-45, TaxInterpretations translation) that the absence of a resolution appointing Gagné should be given little weight given the absence of corporate records since 2005, stated (at para. 48) that “[i]n other contexts, the defence of corporate formalism is of equally little value when it comes up against the totality of the facts of the case” and further stated (at para. 49): In the context of this case, the problem is that the Estate is seeking to exploit a governance defect that the principal never even raised when, on more than one occasion, he had ample opportunity to do so. ...

The Corporation had been restored to financial health, and following a repurchase by the Corporation in September 2005 of all the Class A shares of FRSE and FSTQ for $1.85 million and $2.18 million, respectively, the Holdco of Charles made a paid-up capital distribution to him (in February 2006) of $555,000 (being virtually all of the shares’ paid-up capital). ... Respecting his first finding, he stated (at paras. 64-65, 72-73, TaxInterpretations translation): [T]he evidence … demonstrates that the investment made by the FSTQ in 1998 in Class A common shares as well as the exchange by the FRSE Fund of its share in the Corporation for common shares, were imposed on the Custeau Group by the FSTQ. These transactions did not form part of a tax plan or a long term plan with an objective or goal of crystallizing the capital gains exemption in 2003 and 2004 and reducing capital in 2006. … [T]he capital dilution had already occurred in 1998, at the time of the investment by FSTQ, and is not to be linked to the 2006 capital reduction that produced a tax benefit. … [I]t was financially inconceivable in 1998 for the plaintiffs to one day to be in the position to redeem the investment of FSTQ and FRSE and have enough liquidity to effect a reduction in capital in the neighbourhood of $555,000 each in 2006. ...

. … [T]he Notes… are investments by SLT in debt instruments of BNSIL and TDII, which are non-resident entities. ... It was also unreasonable for CRA to assess all of the increase in value of the Note in the taxation years prior to 2005 (which were statute-barred) in its reassessments for the 2005 taxation year. ...

A sum equal to the share subscription amount was lent by those companies to the trusts and by the trusts to Ardmore, in the latter case under a facility letter dated June 2005. ... There was no default and the Gibraltarian exclusive jurisdiction and governing law clauses would only matter if there was default. … Moreover, the Tribunals looked to the substantive matters rather than theoretical factors, such as causative link and governing law, and so applied a practical approach. ...

Agence du revenu du Québec, 2025 QCCQ 1127-- summary under Subsection 45(1) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1) the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use In 1981, the taxpayers (10 individuals), acquired as co-owners two adjoining rental buildings containing a total of 82 apartments, with their respective undivided interests in such properties ranging from 2.27% to 29.2%. ... Revenue Quebec applied the position in IT-218R on change of use and treated such gains as consisting of a capital gain, computed on the basis of a notional disposition of the properties for their FMV at the time of their change of use from capital property to inventory (in 2005, when the decision to convert was taken) and, as to the balance (representing post-2005 appreciation), as business income from the disposition of inventory. ...