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Paris, a retired KPMG accountant) had followed the advice of Montreal counsel in connection with the settling of the trust including depositing the initial "gift” of the taxpayer to the Trust of $2,000 in the name of the Trust, Owen J found (at paras 67, 68, 69, 70 and 73), and before vacating the reassessments: In my view, the fact that Mr. ...

In connection with its investigation of his past and present tax positions including as to when he ceased to be a U.K resident, the HMRC issued a notice under paragraph 1 of Schedule 36 to the Finance Act 2008 to the taxpayer at his address in Dubai asking the taxpayer to produce information including details of bank and credit card accounts since 6 April 2004 and a schedule of his visits to the UK between that date and 5 April 2013. ...

In 2012, the taxpayer accepted (in connection with waiving any right of appeal pertaining to the 1995 and subsequent years) a settlement agreement which provided that much of the LP losses allocated to the investors would be allowed and that related interest and carrying expenses personally incurred by them also would be allowed and that capital gains from the dispositions of their units would be included in the computation of their income – but was silent as to the treatment of the gains that had been allocated to them by the LPs. ...

MacDonald did not sell his … shares immediately to offset his losses under the forward contract does not sever this connection” (para. 42) “[C]ash settled forward contracts and forward contracts settled by physical delivery are economically equivalent and treating them differently for tax purposes would create ‘an unjustified artificial distinction’.” ...

Ltd. v Li, 2020 BCSC 65-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) CRA could be required to pay excess s. 116 remittance to taxpayer’s mortgagee as directed by taxpayer or to pay into court On a court-approved sale (arising in connection with foreclosure proceedings) of a Vancouver property owned by a resident of Hong Kong (Mr. ...

Given the flow of funds in this tower structure, there is some connection between the interest income paid by USGP and the dividends paid by LLC to USGP, which were reclaimed and reported by Emergis through its partnership interest in USGP. ...

Brooks J effectively applied commentary- that the quoted wording requires “effective personal attachment to a territory” (para. 45) and the effective finding in Crown Forest that full or worldwide taxation is a necessary feature of the connecting criterion but is not sufficient of itself- to find that the mere stapling of the GEFI stock did not give rise to the required connection to the U.S., so that GEFI was not a US treaty resident. ...

In March 2003, in connection with the (planned-since-February 2002) refinancing of the 2002 acquisition, Deutsche Bank advanced $204 million (the maximum amount permitted under the NA thin capitalization rules) to DHNZ in exchange for a convertible note redeemable at maturity in five years’ time at Deutsche Bank’s election by the issuance of a specified number of non-voting shares in DHNZ. ...

In connection with her final declaration above, she noted that: Sifto (which had been cited with approval in Dow Chemical) had indicated that a remedy for unreasonable conduct of the Minister could include issuing an order precluding the Minister from enforcing a penalty assessment or collecting a resulting tax debt (at para. 108); and In light of the circumstances, including that Milgram’s 2021 notices of objection had not yet been adjudicated, “quashing the Minister’s decision to reassess may therefore have the practical effect of ordering the Minister to reconsider her decision” (para. 115). ...

These secured loans had the same or similar terms as the loans referred to above in connection with the investment component, (i.e., a 2028 maturity and 7.85% p.a. interest). ...