Search - 2025年四川高考重本线

Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission transaction documents rectified because they did not implement the parties' intention to not trigger Part IV tax Four individuals held their indirect holdings of 10%, 10%, 5% and 5% of the common shares of a Canadian-controlled private corporation (Structures) through three holding companies (the "Holdcos"). ...

The King, 2025 TCC 24 (Informal Procedure)-- summary under Shared-Custody Parent Summary Under Tax Topics- Income Tax Act- Section 122.6- Shared-Custody Parent two ex-spouses were shared custody parents After initially denying the Canada child benefit (CCB) claims of the taxpayer in full (on the basis that it was her ex-spouse who primarily fulfilled the care responsibilities for their son), CRA assessed her on the basis that they were “shared custody parents,” so that she was entitled to 50% of the CCB amounts. ...

Agence du revenu du Québec, 2023 QCCQ 10239, aff'd 2025 QCCA 234-- summary under Paragraph 111(1)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a) use of Ontario Newcos to permit profitco to hold pref shares of its lossco parent In connection with a September 2009 loss consolidation transaction between a “Lossco” in the Brookfield group (“BRPI”) and its “Profitco” subsidiary (“BEMI”): Two Ontario Newcos with nominal share capital were lent $2.25 billion and $0.525 billion by BRPI pursuant to unsecured demand notes bearing interest at 14%; Each Newco used the loan proceeds to subscribe for non-cumulative preferred shares of BRPI; On the same day, BEMI acquired the Newcos for a nominal amount and they were wound up into BEMI, so that BRPI held $2.275 billion of loans in its subsidiary, and BEMI held $2.275 billion of preferred shares of its parent; and The loans were left outstanding for approximately five months, then: BRPI declared and paid a dividend on the preferred shares to fund the payment of all the accrued interest on the loans, and those shares and loans were redeemed and repaid by way of set-off. ...

The King, 2024 TCC 37, aff'd 2025 FCA 53-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) listing of property on Airbnb engaged s. 141.1(3)(a) The Appellant used a condo unit for the first nine years after purchase for long-term residential rentals and then listed it on Airbnb and rented it out for a succession of short-term rentals (under 60 days and sometimes for only one night) before its sale. ...

Canada (the King), 2025 FCA 53-- summary under Residential Complex Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Complex conversion of the use of a condo from long-term rental to an Airbnb property caused its subsequent sale to be taxable The Appellant used a condo unit for the first nine years after purchase for long-term residential rentals and then listed it on Airbnb and rented it out for succession of short-term rentals (under 60 days and sometimes for only one night) before its sale. ...

The King, 2025 TCC 36 (Informal Procedure)-- summary under Subsection 256(2) Summary Under Tax Topics- Excise Tax Act- Section 256- Subsection 256(2) substantial completion of home renovation occurred on municipal inspection approval Whether the taxpayer had timely filed his application for the Ontario component of the new housing rebate pursuant to s. 256.21(1) for the home of him and his spouse turned on when the substantial renovation of that home was substantially completed (which started the running pursuant to s. 46(6) of the New Harmonized Value Added Tax System Regulations of the two year period for filing the application) and on when the application was filed. ...

The King, 2025 TCC 36 (Informal Procedure)-- summary under Subsection 334(1) Summary Under Tax Topics- Excise Tax Act- Section 334- Subsection 334(1) application was mailed about a month before it was stamped as received by the CRA mailroom Whether the taxpayer had timely filed his application for the Ontario component of the new housing rebate pursuant to ETA s. 256.21(1) for his newly-renovated home turned on when the substantial renovation had been “substantially completed” (which started the running pursuant to s. 46(6) of the New Harmonized Value Added Tax System Regulations of the two year period for filing the application) and on when the application was filed (which, pursuant to s. 334(1) was deemed to be the mailing date). ...

Csak, 2025 FCA 60-- summary under Section 26 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 26 s. 26 extended the time for filing a waiver to the Monday following the expiry of the normal reassessment period on the Sunday The taxpayer challenged assessments of her under s. 160(2) respecting unpaid tax of her late husband for his 1988 and 1989 taxation year by arguing that the assessments of him for those years were statute-barred given that CRA had not received a waiver on a timely basis which, in the case of his 1989 taxation year, turned on the proposition that the receipt by CRA of a waiver on a Monday was one day following the expiry of the normal reassessment period on the Sunday). ...

Csak, 2025 FCA 60-- summary under Subsection 160(2) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(2) a s. 160 challenge confirmed on the basis that a TCC judgment of the transferor was incorrect The taxpayer challenged assessments of her under s. 160(2) respecting unpaid tax of her late husband for his 1988 and 1989 taxation year by arguing that the CRA assessments of him for those years were statute-barred given that CRA had not received a waiver for each year on a timely basis. ...

Csak, 2025 FCA 60-- summary under Subparagraph 152(4)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(ii) s. 26 of Interpretation Act extended the time for filing a waiver to the Monday following the expiry of the normal reassessment period on the Sunday The taxpayer challenged an assessment of her under s. 160(2) respecting unpaid tax of her late husband for inter alia his 1989 taxation year on the grounds that the CRA assessment of her husband for that year was statute-barred given that CRA had received a waiver on the Monday immediately following the expiry of the normal reassessment period on the previous day. ...