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26 February 2020- 12:35am Clément – Tax Court of Canada finds that s. 8(1)(b) did not cover legal costs of an action to extend the period of employment Email this Content 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. ... Respecting his alternative ground- seeking a declaration that the three years during which he acted as a provisional judge be taken into account in the calculating his pension – she noted inter alia that s. 8(1)(b) did not extend to amounts that would have been included in his income under s. 56 rather than s. 5. ...

24 May 2021- 11:04pm Lauzon – Federal Court rejects an unjust enrichment claim by a taxpayer claiming he had not received refund cheques Email this Content The taxpayer alleged that he had not received cheques for refunds claimed in his returns for his 2005 and 2006 taxation years, which CRA’s records showed as having been paid, and brought an action against CRA in 2018 for unjust enrichment on the basis that it had not in fact received the refunds. ... Canada (Revenue Agency) 2021 FC 431 under General Concepts – Unjust enrichment and s. 248(7). ...

24 August 2015- 11:13pm Remtilla – Tax Court of Canada finds that a T1 adjustment request was a waiver keeping the year in question open Email this Content When the taxpayer realized a large loss from options trading in 2008, he decided to report it on income account and filed a T1 adjustment request for his smaller 2005 loss and 2006 and 2007 gains from option trading (previously reported on capital account) to be adjusted to income account. ...

24 November 2019- 11:55pm Holland – Federal Court finds that a taxpayer could not challenge a CRA residency determination that had not yet been assessed Email this Content The taxpayer, who left Canada in 2004 and returned in January 2010, filed a voluntary disclosure application in July 2015 covering the period from 2004 to 2014, but did not file returns for 2005 to 2009, taking the position that for those years he was a non-resident. ...

3 January 2022- 10:50pm Christen – Federal Court finds that a voluntary disclosure planned before, but made after, the audit notification could be considered non-voluntary- but annuls the CRA rejection anyway Email this Content In May 2015, the plaintiff authorized her law firm to represent her in making a voluntary disclosure of her Swiss assets, and in the summer and fall of 2015, various documents were collected and organized to this end. However, on September 25, 2015, CRA sent a letter to the plaintiff indicating that her 2005 to 2014 taxation years were under audit regarding a failure to declare foreign property. ...

20 August 2019- 1:07am Brandimarte – Federal Court reviews CRA decision to partly waive interest that accrued over 35 years, and rejects comparison to those with complete interest relief Email this Content Taxpayers who were the innocent (albeit, perhaps aggressive) victims of a tax fraud, i.e., purported partnerships giving rise to large reported losses in the mid-1980s where, in fact, the partnerships were non-existent, ultimately had their Tax Court actions decided against them in 2014, and sought relief in 2014, or 10 years previously, for accrued interest. ... The lower relief for the 2014 application properly reflected the application to those applicants of the prohibition after a 2005 amendment to going back more than 10 years with interest relief; and the CRA delays were appropriately weighed against the fact that the applicants had had the ability to have their returns assessed so that they could pay the tax and cut off the interest. ... In Ludco … the Federal Court of Appeal held that evidence about other taxpayers who had benefited from an interest deduction for loans obtained in circumstances identical to those of the appellants was inadmissible…. ...

28 January 2018- 11:31pm Gauthier – Federal Court finds that CRA is not precluded from using information received under the VDP to reassess taxation years before the 10-year s. 220(3.1) period Email this Content The applicant transferred $300,000 to a Bahamas bank account in 1978. In order to put his affairs in order for his heirs, he made a voluntary disclosure for his 2005 to 2014 taxation years (i.e., all the years within the 10-year period permitted by s. 220(3.1)), which was accepted by CRA, so that penalties were waived and interest relief provided for those taxation years. 14 months later, CRA on the basis of the information provided under this voluntary disclosure began a review of the applicant’s 1980 to 2004 taxation years with a view to including of unreported income and assessing penalties for failure to file T1135s for those years. ... In refusing this request, Martineau J indicated that, under ss. 165(3) and 171, the Tax Court had the power to cancel an assessment, and stated: …The public interest — i.e. the orderly application of the ITA — takes precedence here over the financial and other inconveniences that the applicant may face by having, like all taxpayers, to follow the normal challenge procedure set out in the ITA. ...

20 October 2020- 11:52pm Vincent – Court of Quebec imputes use of the firm’s Quebec establishments to a “silent” partner having departed from KPMG Canada to France in ousting a Quebec-France Treaty exemption Email this Content In May 2012, a Quebec-resident lawyer, who theretofore had been a partner of KPMG Canada, became a resident of France and started working at KPMG France. ... After quoting a statement in Dunne, 2005 QCCA 739 that “when dealing with a firm, all the members, including a member not residing in Quebec, carry on the business of the firm and thereby exploit all of the firm’s establishments there,” Lareau JCQ indicated that the two amounts allocated to the taxpayer thus were taxable to the taxpayer if he was a member of KPMG Canada in 2013 and 2014. ... Agence du revenu du Québec, 2020 QCCQ 3605 under Treaties – Income Tax Conventions – Art. 7 and s. 96(1)(f). ...

. – Federal Court finds that CRA failed to consider whether late T1135s were filed “voluntarily” for earlier years notwithstanding subsequent years being under review Email this Content A taxpayer had a history of filing its T2 returns late and had been subject to various CRA demands to file them. It then became aware that it should have been filing T1135s respecting some foreign real estate, and it filed late T1125s in March 2015 for its 2005 to 2013 taxation years in reliance on the voluntary disclosure program. ... However, he was unwilling to make the same inference with respect to the earlier years, and there was no evidence that CRA had thought adequately about the proposition that it was perhaps unlikely that in assessing the later returns it would not have focussed on the absence of T1135s for the earlier years – and, in fact, the CRA officer appeared to not realize that those earlier years had already been assessed or, at any rate, was indifferent to that fact. ...