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.$2.9 billion made to settle actions against it in connection with the Enron bankruptcy included whether the settlement amount should have been reimbursed to it by subsidiaries, whose conduct may have been the primary basis for the actions, in accordance with the transfer pricing rules. ...

.$2.9 billion made to settle actions against it in connection with the Enron bankruptcy, the Crown asked CIBC to approach its auditors (“EY”) to ask if they have any documents that matched defined search terms that CIBC used for documentary discovery, and to search for a multi-year period. ...

In concluding that these grants were consideration for a taxable supply of management servicers by the appellant, Rowe DJ. stated (at para 20): Pool Committee Inc. received money each year…to utilize the funds solely in connection with the stated purpose of operating, maintaining and regulating the swimming pool…The Town owned the facility and …chose to pay Pool Committee Inc. to run the pool on a day-to-day basis and it received the exact service which was the subject matter of the payment.... ...

The Queen, 2016 TCC 11 (Informal Procedure)-- summary under Subsection 169(1) Summary Under Tax Topics- Income Tax Act- Section 169- Subsection 169(1) refusal to grant Reg. 105 waiver not an assessment/remedy in Federal Court CRA determined to not grant a waiver of withholding under Reg. 105 from fees to be paid to the appellants in connection with a proposed performance in Canada. ...

The Queen, 2016 TCC 52 (Informal Procedure)-- summary under Benefits-Conferring Legislation Summary Under Tax Topics- Statutory Interpretation- Benefits-Conferring Legislation interpretation to favour conferral of intended benefits In connection with finding that he addition of an accommodation co-purchaser (for financing purposes) of a new condo did not have the effect of denying the new housing HST rebate, Hershfield J stated (at paras. 50-51): In Rizzo & Rizzo Shoes Ltd. ...

ARQ, 2014 QCCQ 8444, partially aff'd 2018 QCCA 518-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) assessments invalid as made against dissolved subsidiary rather than parent, which was liable for the subsidiary’s obligations under QBCA, s. 313 Assessments made by the ARQ of the taxpayer for its 2006 and 2007 taxation years, after it had been dissolved in connection with voluntary dissolution proceedings for its winding-up into its parent, were invalid. ...

Smith allowed the taxpayer’s claim for travel expenses of $30,418, stating (at para. 51): There is an obvious connection to the source of income, and while the amount is substantial, I am unable to conclude that it was unreasonable in the circumstances…. ...

In connection with considering an agency issue, D’Arcy J found that the Appellant had not established that the beneficial interests in Vacation Homes were held by it on behalf of its members, given inter alia that the risk of damage to the property through fire, misconduct of the users or normal wear and tear rested with the Appellant and the Resort Points represented only contractual rights to make reservations rather than being interests in the Vacation Homes. ...

Ernst & Young LLP, 2015 BCCA 445-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault accounting firm exclusion clause was binding The appellant’s B.C. law firm retained Ernst & Young to provide her with U.S. tax advice in connection with negotiating a separation agreement with her husband. ...

The Queen, 2016 TCC 172, aff'd 2018 FCA 124-- summary under Paragraph 20(1)(cc) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(cc) legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales The taxpayer, a Canadian public company listed on the TSX and NYSE and in Europe, incurred substantial legal fees in connection with its decision to make a hostile bid for a French public company (“Pechiney”). ...