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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”). ...

The Queen, 2016 TCC 172, aff'd 2018 FCA 124-- summary under Subsection 169(2.1) Summary Under Tax Topics- Income Tax Act- Section 169- Subsection 169(2.1) raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) In its Notice of Objection, the taxpayer (a large corporation) raised the issue as to whether expenses incurred by it in connection with a hostile bid “were deductible in the computation of the income of Alcan for the period” and listed various paragraphs of s. 20(1) including s. 20(1)(e), but without otherwise advancing any argument that the expenses were deductible under s. 20(1)(e) – which it did not do until it provided written arguments after the completion of the Tax Court hearing. ...

.$2.02 billion pursuant to s. 247(2)(c) in the 2007 income of Petro-Canada as an imputed reimbursement to Petro-Canada by PCUK of the settlement payments, and assessed a s. 247(3) penalty for failure to prepare contemporaneous documentation in connection with the imputed reimbursement. ...

The evidence did not show that there were excesses in the cost of construction or any specific problems with soil contamination or with the connection infrastructure with municipal services, or any errors of development or construction. ...

The evidence did not show that there were excesses in the cost of construction or any specific problems with soil contamination or with the connection infrastructure with municipal services, or any errors of development or construction. ...

After finding that no portion of the $207.5M difference between these two amounts was deductible interest to Amoco, Hogan J indicated obiter that the $207.5M difference might instead be an addition to the cost to Amoco of its Dome Petroleum shares, stating (at para. 110): Because the full amount was due (although not due and payable or immediately exigible) one could assert that the assumed liability forms part of the Appellant’s cost of the shares of Dome Petroleum, for example, in much the same way that legal expenses incurred but not yet paid in connection with the execution of a purchase and sale agreement for shares are included in the cost of those shares. ...

. … Moreover, a close reading of section 225(4)(c) … permits the input tax credit claims to be filed no matter how late the HST may be charged in connection with the subject transaction(s), provided that the HST was not originally charged by the vendor/supplier and the CRA has subsequently assessed the vendor/supplier for that outstanding HST. … ...

General Provisions termination payment that did not come within s. 6(4) should be treated as excluded from s. 6(1)(a) In connection with the Nortel asset distributions, a Nortel health and welfare trust made lump sum payments in 2011 to a benficiary in satisfaction of her entitlement for the trust to pay the periodic premiums for life insurance policies on her life (giving rise to income inclusions to her under s. 6(4)). ...