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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. ...

In connection with the use in the transactions of s. 88(1)(d), Noël CJ stated (at paras 77-78): The bump provided for in paragraphs 88(1)(c) and (d)…essentially allows any ACB that would otherwise be lost on a vertical amalgamation to be preserved and transferred to different property that is taxed the same way. ...

Chad, 2018 FC 319-- summary under Section 37 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Canada Evidence Act- Section 37 CRA had to show and justify why it had to redact materials in order to not shed light on its audit methodology In connection with an application by the taxpayer (the Respondent) to have requirements issued to it by the Minister pursuant to ss. 231.1 and 231.6 set aside on the basis that they were invalid or overly broad, he requested, pursuant to Rules 317 and 318 of the Federal Courts Rules, all material relied on to issue the Requirements. ...

“Stewards,” being persons who had a commercial connection with such waste, were statutorily responsible for paying fees to SO to reflect their reasonable share of the associated costs. ...

.)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) a reassessment of a wound-up and dissolved sub bound its parent The ARQ reassessed the taxpayer for its 2006 and 2007 taxation years a few days after the taxpayer had been dissolved (on March 14, 2011) in connection with voluntary dissolution proceedings for the winding-up of the taxpayer into its wholly-owning parent. ...

Before affirming the finding below that the invoices received by Stamatopoulos satisfied the documentary requirements for claiming input tax refunds, Marcotte JCA stated (at paras. 53-54, 56): [C]ontrary to what was pleaded by the Agency, it matters little whether the person with whom the taxpayer deals directly in connection with a genuine commercial transaction acts as a “supplier” or an “intermediary,” since the provisions of the Regulation respecting the Québec sales tax provide that the invoice must contain the name of the “supplier” or that of the “intermediary” who is authorized by the supplier to cause or facilitate the making of the supply. ...

In granting the order and rejecting the taxpayer’s submission that the request letters were issued in connection with “a criminal investigation going on behind the scenes of which the [CRA] Auditor ha[d] no knowledge,” Russell J stated (at paras 50, 55, 58 and 59): … Offshore accounts are not, per se, illegal and it is the duty of the Minister under the Act to inquire and ensure that those with offshore accounts are meeting their tax liabilities. … If the Respondent’s position were accepted, it would mean that, given the government’s intent to deal with offshore tax offenders, every Canadian taxpayer with an offshore bank account would be immune from compliance with the audit requests made under s 231.1(1) because this could lead to criminal proceedings at some time in the future. ...

In connection with finding (at para. 49, TaxInterpretations translation) that “the real control of the Haifa Trust was exercised by Mr. ...