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News of Note post
23 February 2020- 11:44pm Burlington Resources – Crown abandons its position that s. 247(2)(c) applied to reduce guarantee fees paid by a ULC to its non-resident parent Email this Content Burlington, a Nova Scotia ULC, borrowed approximately U.S.$3 billion in 2001 and 2002 by issuing notes that were guaranteed by its non-resident parent (“BRI”). The Minister reassessed Burlington’s 2002 to 2005 taxation years to deny, under ss. 247(2)(a) and (c), deductions for the “guarantee fees” paid by Burlington to BRI. ...
News of Note post
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. ... 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. ... KPMG, 2024 QCCS 760 under General Concepts – Negligence. ...
News of Note post
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 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. … Neal Armstrong. ...
News of Note post
24 August 2022- 11:22pm Barrs – Federal Court of Appeal finds that disproportionate interest could be cancelled by CRA to compensate for the s. 220(3.1) 10-year limitation and produce horizontal equity Email this Content A group of taxpayers, who were the 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. ... 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. ... Furthermore: 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] …. ...
News of Note post
15 November 2020- 10:37pm Custeau – Quebec Court of Appeal finds that Copthorne does not require the s. 248(10) “in contemplation of” test to be applied on a backwards-looking basis Email this Content When a family small business corporation (the “Corporation”) was in financial difficulty, two Quebec regional development funds agreed in 1997 and 1998 (with an objective of saving jobs) to inject equity capital in the Corporation on terms largely dictated by them. ... The funds’ common shares of the Corporation were repurchased in 2005 (the Corporation had done quite well), and the taxpayers had their Holdcos distribute most of their PUC in cash during 2006. ...
Scraped CRA Website
T2 Corporation – Income Tax Guide – Chapter 3: Page 3 of the T2 return
A farm loss incurred in a tax year ending after 2005 will expire after 20 tax years following the year of loss. ... The current-year restricted farm loss can reduce farm income for the 20 following tax years if the loss was incurred in a tax year ending after 2005 and for the 3 previous tax years. ... Enter each loss by year of origin, starting with the current year, going down to the 20 th previous year for losses incurred in a tax year ending after 2005. ...
FCA
Canada v. Klywak, 2005 DTC 5712, 2005 FCA 354
Klywak, 2005 DTC 5712, 2005 FCA 354 Date: 20051028 Docket: A-521-04 Citation: 2005 FCA 354 CORAM: LINDEN J.A. ... Date: 20051028 Docket: A-521-04 Citation: 2005 FCA 354 CORAM: LINDEN J.A. ... KLYWAK PLACE OF HEARING: Winnipeg, Manitoba DATE OF HEARING: October 20, 2005 REASONS FOR JUDGMENT: Linden J.A. ...
FCA (summary)
Canada (Attorney General) v. Nash, 2005 DTC 5696, 2005 FCA 386 -- summary under Other
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. ...
FCA
Pinto v. Canada (Attorney General), 2005 FCA 162
Canada (Attorney General), 2005 FCA 162 Date: 20050504 Docket: A-201-04 Citation: 2005 FCA 162 CORAM: DÉCARY J.A. ... Judgment delivered at Montréal, Quebec, on May 4, 2005. REASONS FOR JUDGMENT OF THE COURT BY: PELLETIER J.A. Date: 20050504 Docket: A-201-04 Citation: 2005 FCA 162 CORAM: DÉCARY J.A. ...