Effective Date

Commentary

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Cases

St-Pierre v. Canada, 2018 CAF 144

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) retroactive judgment annulling a dividend did not retroactively give rise to a shareholder debt for the annulled amount 608

Anderson v Benson Trithardt Noren LLP, 2016 SKCA 120, aff'd 2017 SCC CanLii 8568

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Tax Topics - General Concepts - Rectification & Rescission drop-down documents could not be declared retroactive to the previously-agreed effective date, as this would undercut the Tax Court 276

Nussey v. Canada, 2001 DTC 5240, 2001 FCA 99

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Stone's Jewellery Ltd. v. Arora, [2000] GSTC 168 (Alta. Ct. Q.B.)

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Sussex Square Apartments Ltd. v. The Queen, [1999] 2 CTC 2143 (TTC), aff'd [2000] 4 CTC 203 (FCA)

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Tax Topics - General Concepts - Stare Decisis 34

Barnabe Estate v. The Queen, 99 DTC 5387 (FCA)

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 42

The Queen v. Larsson, 97 DTC 5425 (FCA)

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Dale v. Canada, 97 DTC 5252 (FCA)

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Tax Topics - General Concepts - Rectification & Rescission retroactive effect of nunc pro tunc rectification order 167
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend 76
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2) 76
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) retroactive validation by Superior Court of preference share issuance was effective for s. 85 purposes 165
Tax Topics - Statutory Interpretation - Provincial Law 134

Greenway v. Canada, 96 DTC 6529 (FCA)

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Kettle River Sawmills Ltd. v. The Queen, 92 DTC 6525 (FCTD)

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property status does not turn on whether CCA actually claimed 63

R. v. Hutton, [1990] 2 CTC 258 (Alta. C.A.)

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Shaw v. The Queen, 89 DTC 5194 (FCTD), aff'd 93 DTC 5213 (FCA)

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Bouchard v. The Queen, 83 DTC 5193, [1983] CTC 173 (FCTD)

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Scandia Plate Ltd. v. The Queen, 83 DTC 5009, [1982] CTC 431 (FCTD)

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Perini Estate v. The Queen, 82 DTC 6080, [1982] CTC 74 (FCA)

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Kingsdale Securities Co. Ltd. v. The Queen, 74 DTC 6674, [1975] CTC 10 (FCA)

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Howard v. The Queen, 74 DTC 6607, [1974] CTC 857 (FCTD)

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Tax Topics - Income Tax Act - Section 60 - Paragraph 60(c) 81

Nelson v. The Queen, 74 DTC 6266, [1974] CTC 360 (FCA)

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 169

Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)

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Rose v. MNR, 73 DTC 5083, [1973] CTC 74 (FCA)

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Minister of National Revenue v. Lechter, 66 DTC 5300, [1966] CTC 434, [1966] S.C.R. 655

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Tax Topics - Income Tax Act - Section 9 - Timing 90

Falconer v. Minister of National Revenue, 62 DTC 1247, [1962] CTC 426, [1962] S.C.R. 664

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See Also

Wise v. The Queen, 2019 TCC 196

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) no immediate taxable benefit to a landlord-shareholder from improvements made to the leased building by the tenant-corporation 339

Black v. The Queen, 2019 TCC 135

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) an ancillary income-earning purpose for making a loan whose terms were never finalized was sufficient to satisfy s. 20(1)(c)(i) 627
Tax Topics - General Concepts - Payment & Receipt advance on another party’s behalf established a loan 135

Trower v. The Queen, 2019 TCC 77 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) purported retroactive dividend would not have been agreed to by both directors at the time 307

Bourgault v. The Queen, 2019 CCI 6

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Tax Topics - General Concepts - Rectification & Rescission a rectification judgment was “justifiably obtained” and, therefore, followed for tax purposes 370

De Vries v The Queen, 2018 TCC 166

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Tax Topics - Income Tax Act - Section 224 - Subsection 224(1) a corporate creditor’s oral agreement to postpone collection of his loan defeated a RTP encompassing that loan 346
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) if requirement to pay assessment had been valid, it would have flowed through with a dividend 290

Melançon v. The Queen, 2018 CCI 73

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) failure of a house construction company to charge a mark-up on its costs incurred for shareholder work generated at taxable benefit/rebooking of “expense” as shareholder advance was retroactive tax planning 326

Mammone v. The Queen, 2018 TCC 24, rev'd 2019 FCA 45

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) RPP revocation beyond the normal reassessment period retroactively validated an unsupportable reassessment under s. 56(1)(a)(i) 398
Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) subsequent retroactive deregistration of RPP also retroactively validated an assessment factually made on basis of plan’s invalidity 200
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) subsequent retroactive deregistration of RPP would not establish carelessness in previous return filing 185
Tax Topics - Income Tax Act - Section 147.1 - Subsection 147.1(12) subsequent deregistration of RPP beyond normal reassessment period nonetheless retroactively validated reassessment 91
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) valid assessment for transfer to an RPP that was retroactively deregistered 83

Cook v. The Queen, 2017 TCC 188 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 118 - Subsection 118(5) court order retroactively terminating support obligation to the taxpayers’ agreement thereon respected – but s. 118(1) claim denied as entailing proration 410

Gillen v. The Queen, 2017 TCC 163, aff'd 2019 FCA 62

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Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) - Subparagraph 110.6(14)(f)(ii) property was not used in a business for s. 110.6(14)(f)(ii) purposes when it was beneficially acquired and dropped-down on the same day 342
Tax Topics - General Concepts - Ownership test of beneficial ownership 108

Deragon v. The Queen, 2015 TCC 294

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Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (a) sales proceeds reduced by subsequent price adjustment clause but included conditional sales proceeds 463
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) reverse earnout amounts included in proceeds 233

Charania v. The Queen, 2015 DTC 1103 [at 614], 2015 TCC 80 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) no shareholder benefit from erroneous property valuation 297

Murphy Estate v. The Queen, 2015 TCC 8

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Words and Phrases
disclaimer
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Tax Topics - Income Tax Act - Section 146 - Subsection 146(8.8) consent order for settlement of estate litigation did not have retroactive effect 195

Al-Hossain v. The Queen, 2014 TCC 379

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Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) co-owner was not occupant and bare trust declaration was too late 260
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) bare trust declaration was too late 126

James v. The Queen, 2013 DTC 1135 [at 705], 2013 TCC 164

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Tax Topics - Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount retroactive court orders 97

Twomey v. The Queen, 2012 DTC 1255 [at 3739], 2012 TCC 310

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Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share records rectified to reflect 24-mo. hold for shares 270

Sommerer v. The Queen, 2011 DTC 1162 [at 845], 2011 TCC 212, aff'd 2012 FCA 207

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Gestion Forêt-Dale Inc. v. The Queen, 2009 DTC 1378, 2009 TCC 255

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Gagnon v. The Queen, 2008 DTC 3111, 2006 TCC 194

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) 135

Avotus Corporation v. The Queen, 2007 DTC 215, 2006 TCC 505

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Lloyd v. The Queen, 2002 DTC 1493 (TCC)

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Fallis v. The Queen, 2002 DTC 1242 (TCC)

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McAnulty v. The Queen, 2001 DTC 942 (TCC)

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Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) unauthorized grant of rights 198

Glassford v. The Queen, 2000 DTC 2531 (TCC)

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Horkoff v. The Queen, 97 DTC 621 (TCC)

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Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) back-dated dividend 65

Leung v. MNR, 92 DTC 1090 (TCC)

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Tax Topics - General Concepts - Fair Market Value - Shares 175

Voukelatos v. MNR, 92 DTC 1076 (TCC)

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Seaman v. MNR, 90 DTC 1909 (TCC)

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Amirault v. MNR, 90 DTC 1330 (TCC)

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Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) Increase to exercise price did not create new option 157

May Estate v. MNR, 89 DTC 534 (TCC)

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Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) 62

Pellizzari v. MNR, 87 DTC 56 (TCC)

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Robert Bédard Auto Ltée. v. MNR, 85 DTC 643 (TCC)

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Spence v IRC (1941), 24 TC 311 (Ct of Sess (1st Div'n))

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Waddington v. O'Callaghan (1931), 16 TC 187 (KBD)

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Administrative Policy

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019

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Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part I - Section 6 445
Tax Topics - Excise Tax Act - Schedules - Schedule VII - Section 13 356
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service assimilation of provision of ovum or embryo to single supply at fertility clinic of institutional health care service 76

27 March 2018 Internal T.I. 2017-0691941I7 F - Investissement frauduleux – Fraudulent Investment

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) s. 152(4.2) reversal of Ponzi interest inclusion must be applied for by 10th anniversary of the taxation year 244
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) Ponzi scheme investors can generally write off their reinvested interest income in the year the perpetrators are charged 267

5 October 2018 APFF Roundtable Q. 15, 2018-0768861C6 F - Share exchange and statute of limitation

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) a price adjustment clause can operate re statute-barred transactions to affect a tax attribute that is used in the current year 244

16 June 2016 External T.I. 2015-0623031E5 F - Application of paragraph 7(1)(b)

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) contingent amount included under s. 7(1)(b), cannot subsequently be excluded 229

9 October 2015 APFF Roundtable Q. 10, 2015-0595671C6 F - Question 10 - Table Ronde APFF 2015

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose generally should be reimbursement for expenses incurred for affiliate 220

2013 Ruling 2013-0488291R3 - Reorganization of Corporations - Rollover

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Tax Topics - Income Tax Act - Section 215 - Subsection 215(6) Spinco taking responsibility for Part XIII remittance obligation of Parent 206
Tax Topics - Income Tax Act - Section 52 - Subsection 52(2) taxable dividend spin-off of thinly capitalized sub 249

29 October 2013 External T.I. 2013-0507881E5 - Price adjustment clause

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) price adjustment payment recognized as s. 84(3) dividend when received 316

25 September 2013 External T.I. 2013-0488571E5 F - Repayment of a dividend

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Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) dividend declared cannot be nullified by subsequent board or shareholder resolution 119

10 June 2013 STEP Roundtable Q. 7, 2013-0480291C6 - 2013 STEP Roundtable Q.7 - Price adjustment clause

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5 October 2012 APFF Roundtable, 2012-0453891C6 F - Price Adjustment Clause

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Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) price adjustment clause that is implemented potentially can prevent s. 75(2) application to estate freeze 305

14 June 2012 External T.I. 2012-0443711E5 F - RAP - Annulation de la vente de l'immeuble

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Tax Topics - Income Tax Act - Section 146.01 - Subsection 146.01(1) - Eligible Amount subsequent court-ordered voiding of home purchase funded with HBP does not affect satisfaction of the HBP conditions 110

24 May 2012 External T.I. 2011-0429991E5 - Price Adjustment Clause

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17 May 2012 Internal T.I. 2012-0437001I7 F - Price Adjustment Clause

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(e.2) no need to file amended s. 85(1) election where PAC engaged 54

8 February 2012 Internal T.I. 2011-0431581I7 F - Sous-alinéa 6(1)a)(vi) proposé

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Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) no penalties if taxpayer promptly refiles after announcement that favourable amendment will not proceed 93
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(vi) “studies” are at all levels and bursaries and tuition reimbursements potentially are included 116

7 October 2011 APFF Roundtable Q. 4, 2011-0412071C6 F - Modifying a Capital Dividend Election

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Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) short-cut method for direct assessment of shareholders for excess amount 132

29 November 2011 Roundtable, 2011-0426361C6 F - Price adjustment clause and redemption of shares

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) deemed dividend arising from preferred share price adjustment clause arises in the year of actual payment 136

6 December 2011 External T.I. 2010-0384701E5 F - Décès contribuable - Immobilisation admissible

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Tax Topics - Income Tax Act - Section 70 - Subsection 70(5.1) application of s. 70(5.1) to bequest of goodwill 198
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) CRA policy for adjusting a statute-barred year for a reduction in the 5th year of staged-proceeds sale 141

21 November 2011 External T.I. 2011-0422191E5 F - Price adjustment clause and redemption of shares

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) price adjustment payment recognized as s. 84(3) dividend when received 52

7 October 2011 APFF Roundtable Q. 23, 2011-0412111C6 F - Validity of Price Adjustment Clause

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(7.1) validity of price adjustment clause does not depend on filing an amended election 93

7 October 2011 Roundtable, 2011-0411851C6 F - Fiducie de protection d'actifs

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Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Testamentary Trust - Paragraph (b) distribution of property from asset protection trust directly, rather than via estate, to testamentary trust would taint it 264

8 June 2010 2010 STEP Roundtable Q. 2, 2010-0363071C6 - STEP Roundtable Q2

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) distribution note can be issued after year end based on administative delays in calculating income 231

8 October 2009 External T.I. 2009-0338861E5 - Backdating of a completed transaction

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14 January 2005 External T.I. 2004-010941

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18 April 2001 Internal T.I. 2001-006946 -

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10 March 1999 External T.I. 5-982912 -

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1996 Corporate Management Tax Conference Round Table, Q.9 (CTO "Plans of Arrangement")

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1996 Calgary Round Table, Q. 17 (961680) (CTO Effective and Closing Date")

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94 CPTJ - Q.19

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92 CR - Q.30

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17 August 1992, T.I. 921353 (April 1993 Access Letter, p. 135, ¶C20-1141)

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91 CR - Q.28

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91 C.R. - Q.41

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91 CPTJ - Q.25

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16 September 1991 TI (Tax Window, No. 9, p. 9, ¶1451)

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25 February 1991 TI (Tax Window, Prelim. No. 3, p. 29, ¶1123)

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10 December 1990 TI (Tax Window, Prelim. No. 2, p. 20, ¶1065)

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Tax Topics - Income Tax Act - Section 128 - Subsection 128(1) 31

90 CR - Q.58

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27 March 1990 TI (August 1990 Access Letter, ¶1364)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 27

14 September 89 T.I. (February 1990 Access Letter, ¶1108)

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Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.6) 36

87 CR - Q.70

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85 CR - Q.52

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 46

80 CR - Q.14

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 15

IT-396R "Interest Income"

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IT-169 "Price Adjustment Clauses"

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IT-216 (Cancelled) "Corporation Holding Property as Agent for Shareholder" 20 May 1975

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Articles

Kevyn Nightingale, John Sorensen, "Backdating of Dividends", Tax Topics (Wolters Kluwer), No. 2392, January 11, 2018, p. 1

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Douglas S. Ewens, Paul Lynch, "Comments on Rectification", 2005 Conference Report, c. 23

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Darcy De Moche, Greg Johnson, "Recent Developments and Transactions Affecting Income Funds and Royalty Trusts", 2005 Conference Report, p. 17:6

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Michel Bourque, "Requirement of Notice to the Canada Customs and Revenue Agency", Tax Litigation, Vol. IX, No. 4, 2001, p. 590.

Jules Lewy, "Making Amends", CA Magazine, January/February 2002, p. 41

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Wilfred M. Estey, "Pre-Incorporation Contracts: The Fog is Finally Lifting", Canadian Business Law Journal, Vol 33, No. 1, February 2000, p. 3.

Wertschek, "The Tax Advisor and Commercial Law: Some Issues", 1993 Conference Report, C. 24, pp. 24:31-39

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Joel A. Nitikman, "When Shares are Issued", Canadian Current Tax, May 1995, Vol. 5, No. 8, p. 79.

Joel A. Nitikman, "Rescission of Contracts for Mistake", Canadian Current Tax, April 1995, Vol. 5, No. 7, p. 63.

Pound, "Remedial Tax Planning: How to Fix It When It's Broke", 1993 Conference Report, c. 9, pp. 9:19 - 21.

Kuzyk, "Selected Aspects of the Interplay Between Tax and Corporate Law", 1990 Conference Report, c. 46, 2012 DTC 1255 [at 3739]