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SPE Valeur – Tax Court of Canada finds that criminally seized documents could be used in a subsequent civil reassessment under s. 163(2)

20 September 2019- 2:02am SPE Valeur – Tax Court of Canada finds that criminally seized documents could be used in a subsequent civil reassessment under s. 163(2) Email this Content The Criminal Investigations Directorate seized records of taxpayers in connection with its investigation, but ultimately returned the file to the audit branch based on a cost-benefit analysis. ...

CRA accepts ONEnergy, including that “either” ETA s. 141.1(3) or 141.01(2) can be satisfied

In this regard, Webb JA found that ETA s. 141.1(3), which provides for an ITC where the service (or property) is acquired in connection with the disposition or termination of a commercial activity, is more specific than s. 141.01(2), so that a person will not lose its entitlement to claim an ITC solely because it was not making any taxable supplies at the time the service (or property) was acquired. ...

CRA finds that shares distributed out of an inter vivos trust on an active individual’s death were received as a consequence of death for s. 120.4(1.1)(b)(ii) purposes

(Regarding GAAR where s. 120.4(1.1)(b)(ii) has been engaged, CRA looks for a sufficient connection between the deceased person and the property that is being distributed, and the specified individual, to support the application of the s. 120.4(1.1)(b)(ii) deeming rule.) ...

Latulippe – Quebec Court of Appeal finds that subdividing a rental property to substantially enhance the sales proceeds did not entail conversion to inventory

In finding that the taxpayers realized capital gains, Rochette JCA noted the absence of any connection between the taxpayers’ employment and real estate or of prior dealings in real estate, their initial intention of generating additional income on retirement and the decision to sell being brought on by changed circumstances, the low cost in dividing into co-ownership units and the low commercial risk associated with this step, and the sale of all the units occurring within the same year. ...

Friedman – Federal Court does not follow its interpretation in Lin that a requirement letter insufficiently specified who was covered

In order to expedite and facilitate our audit, we will require a clear understanding of all entities with which you had a connection or affiliation during the taxation years noted above. … Please send us back the attached questionnaire fully completed within 30 days …. ...

Adou - Court of Quebec finds that a 3-year departure from Quebec entailed a 3-year cessation of ordinary residence

Breault, J.C.Q. found that the taxpayer’s “customary lifestyle and ordinary mode of living, on December 31, 2013, was in the Province of Ontario” in light of the taxpayer having severed most of his connections with Quebec (e.g., his apartment and family both moved), and also noted: [His] visits to Quebec (during the relevant period) … were clearly only temporary and limited in nature. ...

CRA disagrees that project expenses incurred after determining economic feasibility and before project approval are generally deductible

26 March 2020- 11:58pm CRA disagrees that project expenses incurred after determining economic feasibility and before project approval are generally deductible Email this Content Rio Tinto found that investment dealer fees incurred in connection with an acquisition but before the board determined to make the acquisition were fully deductible. ...

CRA confirms that the “cost” of call options closed out by their writer is nil, and that the “cost” of a short sale is the FMV of the borrowed shares

CRA confirmed its position “that expenses incurred in connection with the granting of an option may be deducted from the proceeds of disposition when calculating a taxpayer's gain.” ...

Filion – Court of Quebec finds that an office holder received no taxable benefit from improper expense charges which were docked from his compensation early the next year

The National Assembly got wind of this impropriety in January 1999, and stopped payment on a taxable transitional allowance of $53,000, that was payable to him in connection with his defeat in the election. ...

4053893 Canada – Federal Court finds that a disclosure by a company was reasonably treated by CRA as not voluntary given enforcement action against its sole shareholder

McHaffie J found that it was reasonable for CRA to determine that the company’s disclosure was not voluntary given the close connection between that disclosure and the enforcement action being taken against the individual, including that his returns would disclose his income from the company, and in the telephone conversation with CRA, it had been informed that the company was still active. ...

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