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Pomeroy’s Masonry – Federal Court finds that CRA failed to consider the taxpayer’s need to apply an income tax credit to pay HST arrears

Southcott J directed CRA to reconsider the taxpayer’s request on the basis that it was inappropriate for CRA to rigidly follow those guidelines, rather than also taking other relevant considerations into account including the policy in favour of letting a taxpayer pay off tax debts and the taxpayer’s allegation that CRA’s refusal could render him bankrupt. ...

Greither Estate – B.C. Supreme Court finds that taking back excess boot cannot be rectified under the BCA provision for correcting “corporate” mistakes

After it had been assessed for withholding tax as a result of transferring its shares of the company to a related company for consideration consisting mostly of a promissory note, it applied for relief pursuant to s. 229 of the B.C. ...

The MLI is estimated to be effective for most calendar-year Canadian taxpayers starting January 1, 2020

There will be significant consideration to including those treaties where there would be a match prior to ratification. ...

CRA indicates that a bad debt credit cannot be claimed for uncollectible GST/HST assessed on audit

CRA stated: [S]ection 232 does appear to offer a solution where the consideration is reduced. ...

Referred Realty – Federal Court sets aside a CRA decision not to apply a credit under s. 221.2 based on the taxpayer’s slowness in filing returns

Campbell J set aside this decision on the basis that this did not constitute “a clear and supportable justification to deny the Applicant’s re-appropriation request given the large sum of money under consideration” and it constituted “the delivery of a punishment to the Applicant for perceived failure to meet the [Minister’s] Delegate’s unclear expectations.” ...

CRA notes that two unrelated 50% shareholders potentially could both be related to the corporation based on Duha USA rights and s. 251(5)(b) rights

Respecting where two unrelated individuals each held exactly 50% of the (voting common) shares of the employer, CRA noted that under Duha, “the determination of whether a person exercises de jure control … must also take into consideration whether any specific or unique limitation on a shareholder’s power to control the election of the board or the board’s power to manage the business and affairs of the company, is manifested in either the constating documents of the corporation, or any unanimous shareholder agreement” (USA), so that either individual could have de jure control and be related to the employer under s. 251(2)(b)(i). ...

The proposed restructuring of Banro entails its effective emigration to the Caymans

In particular, Banro’s shares of BGB will be cancelled, BGB will issue shares to a newly-formed Caymans company (Newco) for nominal consideration, and the secured creditors will receive shares of Newco in satisfaction of their secured claims against BGB – except that 25% of their claims will instead be treated as unsecured claims. ...

Choice Properties is proposing to acquire CREIT with a choice of cash, or Choice units issued on a s. 132.2 merger

1 April 2018- 11:29pm Choice Properties is proposing to acquire CREIT with a choice of cash, or Choice units issued on a s. 132.2 merger Email this Content The proposed acquisition of CREIT (which is a closed-end REIT holding most of its properties directly or through subsidiary LPs) by Choice Properties- which is an Ontario open-end REIT holding a partial interest in a property-holding LP (Choice Properties LP)- would occur for aggregate consideration of approximately $1.7B in cash and Choice Properties units valued at around $2.1B. ...

626468 New Brunswick – Tax Court of Canada finds that safe income was reduced by corporate income taxes that would be computed on that income

1 June 2018- 12:27am 626468 New Brunswick – Tax Court of Canada finds that safe income was reduced by corporate income taxes that would be computed on that income Email this Content An individual rolled his apartment building into a Newco in consideration for a mortgage assumption and shares with nominal paid-up capital, and then rolled those shares into a new Holdco. ...

Toronto-Dominion Bank – Federal Court finds that the deemed trust for unremitted GST defeated the mortgagee’s priority on a voluntary sale of the mortgaged home

Similar considerations arise under other statutes, e.g., ITA s. 227(4.1). ...

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