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St-Joseph argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

St-Joseph argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

In finding that the taxpayer was resident in Ontario for his 2017 to 2019 taxation years, the ones assessed by the ARQ, Bourgeois JCQ indicated that: the taxpayer had Ontario rather than Quebec health insurance and had an Ontario driver's license. although he would stay at a condominium in Montreal, these were only temporary stays in connection with the supervision of Montreal properties, and the condo was not used as a personal residence. the place which he considered to be his home was his Ontario farm; and his days each year in Quebec were mere sojourning for the purpose of attending to his rental investments and using his vacation properties there. ...

PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86, aff'd [2025] HCA 30-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt there can be no payment by direction unless there is an antecedent obligation by the creditor to the third party A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the “Bottler”) pursuant to which an Australian subsidiary of PepsiCo (the “Seller”) sold concentrate to the Bottler and PepsiCo granted the Bottler the right to use the Pepsi and Mountain Dew trademarks in connection with its sales of the soft drinks. ...

The Queen, docket 98-2383(IT)G (TCC)-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) GAAR not to be used to fill in gaps of specific anti-avoidance provisions The taxpayer, who owned a portion of the shares of the holding ("GH") which, in turn, owned an operating company ("GBC") utilized the enhanced capital gains exemption in connection with the sale of a cement plant operated by GBC through the following transactions: the taxpayer and the other shareholders of GH transferred a portion of their shares of Holdings to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to Holdings; Holdings redeemed the common shares held in its capital by Newco by transferring to Newco the assets it had received from GBC; and the shareholders of Newco's sold their interests in Newco to the purchaser (who also purchased the remaining cement-plant assets directly from GBC). ...

Redrow Group plc, [1999] UKHL 4, [1999] 2 All ER 13, [1999] 1 WLR 408-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) As an incentive to purchasers of its new homes, a residential home developer entered into agreements with prospective purchasers and real estate agents selected by it under which it agreed to pay the agent's fee plus VAT in connection with a sale of the existing purchaser's home, provided that the purchaser completed a purchase of a new home. ...

In connection with giving his (final) order approving the revised plan, he stated (at para 16): a) the shareholder approval increased from 80% for the original Exxon Arrangement to over 90% for the new Arrangement. ...

The taxpayer wished to recover (via deduction against the outputs of a separate investment business) a proportion of VAT expenses incurred in connection with the deposit-taking business. ...

Rousseau left Quebec solely for work purposes and that he never had the intention to sever his connections with Quebec, which was the place with which he maintained his strongest links between 2003 and 2011. ...

In connection with finding (at para. 50, TaxInterpretations translation) that “the assessment of Motostar was completely void, having been made respecting a non-existent person without legal standing”), Cameron JCQ noted the contrast in wording between s. 306 of the Business Corporations Act (Quebec) (“QBCA”) (which did not apply to the type of dissolution engaged in by Motostar) and s. 313 (which did). ...