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As to the Applicant's argument that the missing information was already filed with CRA in connection with its 2013 SR&ED claim and should have been utilized for purposes of its 2012 claim… [i]t is significant that Form T661 specifically requests information in relation to only the one tax year for which the SR&ED claim is made. ...

The Queen, 2016 TCC 172, aff'd 2018 FCA 124-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 The taxpayer, a Canadian public company listed on the TSX, NYSE and LSE, incurred fees (mostly of investment dealers, law firms, and a French lobbying and public relations firm (“Publicis”)) in connection with its decision to make a hostile bid for a French public company (“Pechiney”) and the subsequent making and completion of that bid late in 2003. ...

The Queen, 2016 TCC 172, aff'd 2018 FCA 124-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations The taxpayer (“Alcan”) incurred various investment dealer, legal and other fees in connection with its successful hostile bid for most of the shares of a French public company (“Pechiney”). ...

Although s. 18(1) of the Commissioners for Revenue and Customs Act 2005 provided: Revenue and Customs officials may not disclose information which is held by the Revenue and Customs in connection with a function of the Revenue and Customs s. 18(2)(a)(i) provided that s. 18(1) did not apply to a “disclosure … made for the purposes of a function” of HMRC. ...

Patten LJ then stated, in connection with finding that ANL was entitled to input tax under the Sveda principle (at paras 48, 51): [I]n economic terms, the cost of purchasing the vouchers was also part of ANL's overall expenditure in the production and sale of its newspapers which the vouchers were intended to promote. ...

Canada, 2017 FCA 131-- summary under Onus Summary Under Tax Topics- General Concepts- Onus required to prove on balance that relevant facts assumed by CRA (where not peculiarly in its knowledge) were incorrect The only issue before the Court was whether the Tax Court had erred, in connection with the taxpayer’s appeal of a net worth assessment, in finding that the taxpayer’s father had not lent him a total of $90,000 during the relevant period. ...

Shortly thereafter, the trustee in bankruptcy who previously had been appointed to lead in connection with filing of the previous unsuccessful filing of a proposal, was replaced. ...

France (2017), No. 1505113/1-1 (Tribunal Administratif de Paris)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Google through its contracting arrangements with French advertisers avoided a French PE A French company (“Google France”) agreed pursuant to a Marketing and Services Agreement (the "Agreement") with a sister corporation (“Google Ireland”) to provide marketing assistance to Google Ireland in connection with the Google “AdWords”) program in France (under which French advertisers paid “per click” amounts for having their messages appear alongside related Google search results) in consideration for being reimbursed for its costs plus an 8% margin. ...

., that no statutory language used in or in connection with subsection 118(1) indicates that the deductions may be prorated for a taxation year, noting in contrast with other provisions in the Act by which Parliament has explicitly provided for proration. ...

There has not been: (a) a breach of a provision of the BCA, a former Company Act or the regulations under any of them; (b) a default in compliance with the memorandum, notice of articles or articles of the company; and … (c) none of the following proceedings at or in connection with any of the following have been rendered ineffective: (i) a meeting of shareholders; (ii) a meeting of the directors or of a committee of directors; (iii) any assembly purporting to be a meeting referred to in subparagraph (i) or (ii); and (d) a consent resolution or records purporting to be a consent resolution has not been rendered ineffective. … [T]he mistake of not completing the Transaction in the most tax effective manner does not … fall within these subsections. ...