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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. ...

.)-- 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. ...

Davis had certain connections of a personal and economic nature. The largest value of Mr. ...

., 2018 FCA 124-- summary under Paragraph 20(1)(bb) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company The taxpayer (“Alcan”), a Canadian public company listed on the TSX and NYSE and in Europe, incurred fees (mostly of investment dealers, law firms and a French lobbying and public relations firm 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 two issues were "the taxability issue"--whether the settlement sum was taxable employment income as "payments and other benefits which are received [by the relevant person] directly or indirectly in consideration or in consequence of, or otherwise in connection with- (a) the termination of a person's employment"; and, if so, "the exemption issue"--whether the settlement sum (or any part of it) was taken out of the above charge to tax by a statutory exemption (“s. 406”) for a payment provided "on account of injury to … an employee", the alleged injury being the injury to the taxpayer's feelings sustained in the context of his age discrimination claim. ...

., [2018] HCA 59-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14.1- Paragraph (a) goodwill must have a connection to attracting custom Whether the acquisition by Barrick Gold Corporation ("Barrick") of another Canadian public company, namely, Placer Dome Inc. ...