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The King, 2023 TCC 45, aff'd 2025 FCA 27-- summary under Specified Provincial Input Tax Credit Summary Under Tax Topics- Excise Tax Act- Section 236.01- Subsection 236.01(1)- Specified Provincial Input Tax Credit Bell Canada received single supplies of electricity from its Ontario electricity suppliers so that their full charges were subject to provincial ITC recapture The appellant (Bell Canada) was required as a result of ETA s. 236.01 and Part 6 of the New Harmonized Value-added Tax System Regulations, No. 2 (the “Recapture Regulations”) to recapture 100% of the input tax credits that it claimed in respect of the 8% tax that it paid under s. 165(2) on the consideration for the supplies to it in Ontario of electricity. ...

The Queen, 2017 TCC 212 (Informal Procedure)-- summary under Substantial Renovation Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Substantial Renovation gutting only half the rooms in a house did not qualify The taxpayer appealed a decision of the Minister to reject his claim for a GST new housing rebate on the basis that the building “looked like new”, the CRA’s analysis was flawed, and that drywall should be excluded from consideration. ...

In rejecting the Crown's position that such 20% share was taxable consideration for administrative, billing and marketing services supplied to the sleep physicians by MedSleep, Bodie J found that: The fee-sharing agreements were valid for tax purposes notwithstanding that, under provincial health care law, payments for physicians’ services could be made by the provincial health insurance plans to physicians only; and The fee-sharing agreements did not contemplate that MedSleep would provide the alleged admin and marketing services to the sleep physicians and they instead indicated that MedSleep was entitled to a portion of the professional fees generated from medical services provided to the patients. ...

Souty and Virtuose selling special voting shares of W4N to EMC Canada for nominal consideration so as to effect an acquisition of control of W4N and a resulting year end. The balance of the shares of W4N now being sold directly, or through a sale of the balance of the Virtuose shares, for cash consideration of over $15 million, such that Souty Holdco and Virtuose reported capital gains of around $4.7 million each (reflecting a reduction for the ACB bump in step 1), and modest capital gains were reported by Souty and Foix on the sale of their respective shares for about $0.8 million each (having regard to their purported s. 110.6 ACB step-up in step 2 to $0.75 million). ...

Approximately half way through construction, the Province decided that there would not be a new university, the agreements were terminated, and (after negotiations) a settlement agreement was entered into among the five parties in which Tech BC agreed on behalf of itself and the Province to pay $41.1M to ICBC in consideration for ICBC, IPL and Mall Co releasing Tech BC and the Province from all obligations under the project agreements. ...

(theretofore, a wholly-owned subsidiary, and a successor by amalgamation to UNAC and the U.S. parent of UNAC, and holding Univar Canada) to (newly-incorporated) UHI for notes and common shares of UHI, UHI transferred those Univar Inc. shares to (newly-incorporated) UHC for notes and common shares of UHC, and Univar NV transferred its remaining shares of Univar Inc. to UHC for a note which then was assumed by UHI in consideration for issuing common shares. ...

Similarly, respecting the divestiture-related fees of Lazard Frères incurred up to board approval of a butterfly spin-off, these related to advice and approaches to potential third-party purchasers of the shares through which the laminated products business was held as well as to the ultimate sale (on a rollover basis) of the shares of that laminated products company to Novelis in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis, and the calculation of the Lazard Frères success fee did not represent a percentage of the value of those shares – so that those fees also were deductible under s. 20(1)(bb) as well as under s. 9. ...

In concluding instead (at para. 145) that “income taxes at the shareholder level should not be taken into consideration in the determination of the fair market value of the shares of Holdco,” Lafleur J stated (at para. 150): [T]here is no reason to believe that Holdco will be liquidated in the near future. ...

Finally, he stated (at para. 436): [T]he fact that the reasonably expected gross income is expected to be realized on December 31, 2028 is not a consideration raised by paragraph 20(1)(c) of the ITA. ...

The Queen, 2018 TCC 102, aff'd 2020 FCA 115-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) the starting ACB of a partnership interest was determined exclusively under s. 97(2)(b)/ no requirement to issue units In 2003 and 2004, the taxpayer (“Iberville”) contributed shopping centres worth $130M and with a cost base of $14M and received non‑share consideration or boot of $8.5M. ...