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Ltd. v Li, 2020 BCSC 65-- summary under Subsection 164(1) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(1) CRA could be directed to pay an excess s. 116 remittance to the taxpayer’s secured creditors No s. 116 certificate was obtained on a court-approved sale of a Vancouver property (arising in connection with foreclosure proceedings) by the Hong Kong owner (Mr. ...

In rejecting Roofmart’s reliance on the statement in Hydro-Québec that "[w]hen the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition," Rennie JA stated (at para 37) that this “passage is not a legal test but analysis of whether, on the facts of that case, there was an ‘ascertainable group’ and whether the information was required for the purposes of verifying compliance,” and that ”the suggestion in the reasons that the information sought was available through other means and therefore could not be obtained through a UPR [unnamed person requirement] is inconsistent with this Court’s jurisprudence, and ought not to be followed.” ...

The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115-- summary under Paragraph 250.1(a) Summary Under Tax Topics- Income Tax Act- Section 250.1- Paragraph 250.1(a) s. 250.1 applies only to persons who would not be taxpayers under Oceanspan An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his purported unused tuition tax credits as a deduction from Canadian tax. ...

The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115-- summary under Taxpayer Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxpayer an individual not within s. 2(1) or (3) was not a taxpayer who could generate a tuition tax credit An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his purported unused tuition tax credits as a deduction from Canadian tax. ...

He also found (at para. 133) that the various trips challenged by the ARQ had been established by Pelletier to be “necessary and incidental to trips that were solely commercial,” including some helicopter-ferrying to close down a fishing camp that had been used for client entertainment and the helicopter’s use in connection with training a pilot. ...

Although the Court has concluded that the Income Funds were not qualified investments for RRSP purposes, and while it certainly finds that the Appellant had ulterior motives in connection with his RRSP, that is not sufficient to reach a finding that the Income Funds were “window dressing”. ...

PVL purchased three pieces of equipment (a wheel loader, compact excavator, and hydraulic thumb) and used them exclusively for the handling of materials already gathered by a cable shovel in connection with the washing, sorting and crushing of the various products intended either for sale (as to about 73% of the products) or for use by PVL (as to the balance). ...

PVL purchased three pieces of equipment (a wheel loader, compact excavator, and hydraulic thumb) and used them exclusively for the handling of materials already gathered by a cable shovel in connection with the washing, sorting and crushing of the various products intended either for sale (as to about 73% of the products) or for use by PVL (as to the balance). ...

Their claim was granted in part, for damages suffered by the plaintiffs in connection with their dismissal. ...

Furthermore, she found that 9267 had not taken reasonable measures to pursue collection of its debt, including claiming under its security interest, and having its debt included in the debtor claims made against 9210 in connection with the receivership and bankruptcy proceedings. ...