Cases
Chappell v Revenue and Customs Commissioners, [2016] BTC 36, [2016] EWCA Civ 809
A tax avoidance scheme failed to achieve the targeted income tax shelter. In particular, relief under SI 1993/2004, Reg. 2B(3), which allowed a...
UBS AG v Commissioners for HMRC; DB Group Services (UK) Ltd v. Commissioners for HMRC, [2016] UKSC 13
In order to avoid income tax employees of the respondent banks were not paid bonuses in cash, but instead were awarded redeemable shares in...
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| Tax Topics - General Concepts - Fair Market Value - Shares | shares’ value reduced by contingent obligation to sell at discount to NAV | 307 |
Schofield v. R & C Commrs., [2012] EWCA Civ 927 (CA)
In order to shelter a capital gain which he had realized, the UK taxpayer purchased two options on the FTSE 100 index to be settled in cash: a put...
2529-1915 Québec Inc. v. Canada, 2009 DTC 5023 [at 5585], 2008 FCA 398
Overview of facts. The two individual taxpayers devised a scheme to: generate artificial capital gains of $110 million in some home-grown...
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| Tax Topics - General Concepts - Sham | capital dividend elections for distributions of what should have been known to be income-account gains were shams | 266 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | shares premiums received for marketing tax scheme were business income | 213 |
| Tax Topics - Income Tax Act - Section 83 - Subsection 83(2) | capital dividend elections for distributions of what should have been known to be income-account gains were shams | 718 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | shares acquired for immediate resale as part of capital dividend account generation scheme were on income account | 177 |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | shares premiums received for marketing tax scheme were business income | 223 |
Canada v. Nunn, 2007 DTC 5111, 2006 FCA 403
In finding that the trial Judge has erred in finding that the investment of the taxpayer's RRSP in worthless shares as a result of fraudulent...
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| Tax Topics - General Concepts - Sham | misrepresentation element of sham | 87 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | sham finding not argued | 51 |
Backman v. Canada, 2001 DTC 5149, 2001 SCC 10, [2001] 1 S.C.R. 367
Before going on to find that the taxpayers had not become partners of a putative partnership by virtue of their arrangements because they lacked...
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| Tax Topics - General Concepts - Purpose/Intention | motivation v. purpose | 65 |
| Tax Topics - Income Tax Act - Section 96 | essential Canadian elements of partnership not present as only momentarily "partners" in common | 298 |
| Tax Topics - Statutory Interpretation - Provincial Law | foreign "partnership" must have the attributes of a Cdn partnership | 153 |
Singleton v. Canada, 2001 DTC 5533, 2001 SCC 61, [2001] 2 S.C.R. 1046
Major J. stated (at p. o) that:
"The Court in Shell emphasized that taxpayers are entitled to structure their transactions in a manner that...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | qualifying direct use where borrowed funds used to refinance partnership capital account, with personal withdrawal | 131 |
Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62
Before going on to find that the taxpayer had effectively generated net deductions by investing in a tax-deferred offshore investment, Iacobucci...
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| Tax Topics - General Concepts - Purpose/Intention | objective and subjective manifestations of purpose | 104 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | ancillary purpose of earning (1%-yield) dividend income/allocation of reinvested proceeds 100% to income-producing source | 414 |
| Tax Topics - Statutory Interpretation - Certainty | 103 |
Ledoux c. La Reine, 2000 DTC 6465, 2001 FCA 130 (FCA)
The Court affirmed (at p. 6466) the findings of the trial judge that a series of complex transactions comprising 43 stages that were completed...
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| Tax Topics - General Concepts - Sham | documents did not reflect actual transactions | 70 |
McEwen Bros. Ltd. v. The Queen, 99 DTC 5326, [1999] 3 CTC 373 (FCA)
In finding that a purported partnership agreement was not a sham, Robertson J.A. stated (at p. 5330):
"In short, to qualify as a sham, the...
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|---|---|---|
| Tax Topics - General Concepts - Sham | deception of Minister | 50 |
| Tax Topics - Income Tax Act - Section 96 | purported partners did not jointly manage or provide capital | 87 |
Shell Canada Ltd. v. Canada, 99 DTC 5669, [1999] 3 S.C.R. 622, [1999] 4 CTC 313
After referring to arguments, based on decisions in Bronfman Trust and Stubart, that courts should look through transactions that impose tax...
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| Tax Topics - General Concepts - Substance | legal relationships prevail over economic realities | 201 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | borrowing in legal substance was in weak currency | 174 |
| Tax Topics - Income Tax Act - Section 67 | s. 67 does not apply where provisions, having their own internal limiting clauses, apply | 96 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | FX hedging gain was capital gain as hedged borrowing was on capital account | 225 |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | 96 |
Canada v. Ferrel, 99 D.TC 5111, [1999] 2 CTC 101 (FCA)
After referring to the statement in Neuman (98 D.TC 6297) that "taxpayers can arrange their affairs in a particular way for the sole purpose of...
Duha Printers (Western) Ltd. v. Canada, [1998] 1 S.C.R. 795, 98 DTC 6334, [1998] 3 CTC 303
In finding that the transactions under consideration had successfully avoided the change-of-control provisions of the Act, Iacobucci C.J. stated...
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| Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(c) - Subparagraph 251(2)(c)(i) | 269 |
Continental Bank of Canada v. R., [1997] 1 CTC 13, 96 DTC 6355
Before finding that the taxpayer had failed to accomplish a tax-motivated plan because it had failed, in law, to establish a partnership with two...
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| Tax Topics - General Concepts - Sham | no sham if docs reflect legal reality | 92 |
| Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) | no rollover because partnership not established | 228 |
The Queen v. Fording Coal. Ltd., 95 DTC 5672 (FCA)
Before finding that former s. 245(1) applied to deny the deduction of resource pools that otherwise would have been available to the taxpayer...
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| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 143 |
Attorney General of Canada v. Hoefele, 95 DTC 5602, [1996] 1 CTC 131 (FCA)
Before finding that a mortgage interest rate subsidy was not a taxable benefit, notwithstanding that other methods of compensating the...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | interest rate subsidy did not increase net worth | 102 |
| Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(1) | new mortgage debt of relocated employees | 125 |
The Queen v. Friedberg, 92 DTC 6031, [1992] 1 CTC 1 (FCA)
Before going on to find that the value of textiles donated to the Royal Ontario Museum did not give rise to a charitable deduction to the taxpayer...
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| Tax Topics - General Concepts - Substance | 117 | |
| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | 212 |
C&E Commissioners v. Music and Video Exchange Ltd., [1992] BTC 5028 (Q.B.)
Before finding that an arrangement which had been described in the relevant documents as an agency relationship should be respected as such,...
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| Tax Topics - General Concepts - Agency | 53 |
Alberta Gas Ethylene Co. Ltd. v. The Queen, 89 DTC 5058, [1989] 1 CTC 135 (FCTD), aff'd 90 DT 6419 (FCA)
An argument that a U.S. subsidiary of the taxpayer - which had no business premises, no employees and no function other than to on-lend a loan to...
A.G. Securities v. Vaughan, [1988] 3 WLR 1205 (HL)
The landlord, by separate but identical agreements entered into contemporaneously, granted a young man and his girlfriend the purportedly...
Craven v. White, [1988] BTC 268 (HL)
Lord Oliver stated:
"As the law currently stands, the essentials emerging from Furniss v. Dawson appear to me to be four in number:
- that the...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) | a series if no real likelihood that the successive transactions will not occur | 155 |
Doncaster v. Smith, [1987] 5 WWR 444 (BCCA)
The receiver-manager of three companies was negligent for realizing recapture and a capital gain on the sale of one of the company's depreciable...
Consolidated-Bathurst Ltd. v. The Queen, 85 DTC 5120, [1985] 1 CTC 142 (FCTD), aff'd on different grounds, 87 DTC 5001, [1987] 1 CTC 55 (FCA)
A captive Bermudan insurance company was found to be a legal entity distinct from its ultimate Canadian parent, and accordingly interest income...
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| Tax Topics - Income Tax Act - Section 138 - Subsection 138(1) - Paragraph 138(1)(a) | 38 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 148 |
The Queen v. Parsons, 84 DTC 6447, [1984] C.T.C 354, 84 DTC 6452 (FCA)
It was found by the trial judge that management companies, which two professional engineers ("Parsons" and "Vivian") had incorporated and...
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| Tax Topics - General Concepts - Sham | no sham as purported legal rights were created | 117 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 117 | |
| Tax Topics - Income Tax Act - Section 9 - Related Companies | 117 |
R. v. Redpath Industries Ltd., 84 DTC 6349, [1984] CTC 483 (Que. S.C.)
Although the operations of a Bermudan company were directed and conducted by its parent companies, the Bermudan company nonetheless was treated as...
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| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(d) | 50 | |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | 32 |
Stubart Investments Ltd. v. The Queen, 84 DTC 6305, [1984] CTC 294, [1984] 1 S.C.R. 536
A transaction should not "be disregarded for tax purposes solely on the basis that it was entered into by a taxpayer without an independent or...
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|---|---|---|
| Tax Topics - General Concepts - Sham | taxpayer-created facade | 132 |
| Tax Topics - Income Tax Act - Section 245 - Old | 33 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 24 |
Furniss v. Dawson, [1984] 2 WLR 226, [1984] AC 474 (HL)
Where a pre-ordained (or pre-contracted) series of transactions contains steps that were inserted without any commercial purpose apart from...
The Queen v. Houle, 83 DTC 5430, [1983] CTC 406 (FCTD)
There is no need for a purchase by a private company to be recorded in minutes or other written memoranda in order for such purchase to be effective.
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 60 |
The Queen v. Special Risks Holdings Inc., 83 DTC 5046, [1983] CTC 36 (FCA)
Where there was no allegation of facts in the Queen's Statement of Defence which would establish a sham, lack of valid business purpose,...
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 448(1) | 99 |
I.R.C. v. Burmah Oil Co. Ltd., [1982] BTC 56 (HL)
A preordained series of transactions that had the apparent result of the taxpayer suffering a loss of almost the whole price that it had paid for...
The Queen v. Malone, 82 DTC 6130, [1982] CTC 145 (FCTD)
It was accepted (before finding against the taxpayer on another ground) that he was in the stockbrokering business on his own account...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 82 |
W.T. Ramsay Ltd. v. l.R.C., [1982] A.C. 300, [1981] UKHL 1 (HL)
In order to realize a capital loss that could be deducted from a chargeable gain that had been realized by him, the taxpayer bought shares in a...
Quemet Corp. v. The Queen, 81 DTC 5359, [1981] CTC 472 (FCTD)
The taxpayer knowingly assisted its suppliers to defraud the Department of National Revenue or dispose of stolen property, by paying them in cash....
The Queen v. Daly, 81 DTC 5197, [1981] CTC 270 (FCA)
The purported interposition between the taxpayer and his employer of a management corporation was legally ineffective, and thus, also ineffective...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 86 | |
| Tax Topics - Income Tax Act - Section 9 - Related Companies | 86 |
Spur Oil Ltd. v. The Queen, 81 DTC 5168, [1981] CTC 336 (FCA)
It was stated that the question of whether a "quotation letter", which the Crown submitted set an artificially high purchase price for oil, was a...
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| Tax Topics - Income Tax Act - Section 245 - Old | 115 |
Fraser Companies, Ltd. v. The Queen, 81 DTC 5051, [1981] CTC 61 (FCTD)
"There is no relationship of principal and agent between the shareholders of a company and the company. The fact that the sole shareholder of a...
Agar v. The Queen, 80 DTC 6311, [1980] CTC 397 (FCTD)
As there was no evidence to support the taxpayer's contention that fees for performing construction work were earned by a company controlled by...
R. v. Campbell, 80 DTC 6239, [1980] CTC 319, [1980] 2 S.C.R. 256
The fact that the taxpayer surgeon responded to regulations, requiring that OHIP be billed in the name of an individual doctor, by billing for...
Feinstein v. The Queen, 79 DTC 5236, [1979] CTC 329 (FCTD)
It was found "that to look at the true situation realistically", the individual taxpayer was acting on behalf of his company when he signed a...
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| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 39 |
Atinco Paper Products Ltd. v. The Queen, 78 DTC 6387, [1978] CTC 566 (FCA)
After finding that an income-splitting "scheme" was ineffective because two supposed trusts had not been properly established, Urie, J. stated:...
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| Tax Topics - General Concepts - Evidence | 18 | |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 69 |
The Queen v. Esskay Farms Ltd., 76 DTC 6010, [1976] CTC 24 (FCTD)
The taxpayer, wished to sell land to the City of Calgary in consideration for two annual instalments in order to defer a portion of the gain to...
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| Tax Topics - General Concepts - Agency | weight given to written agreement terms in finding that intermediary purchased as principal | 122 |
| Tax Topics - General Concepts - Evidence | 81 | |
| Tax Topics - General Concepts - Sham | no sham if documents describe intended legal rights | 354 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 143 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | 199 | |
| Tax Topics - Income Tax Act - Section 245 - Old | 57 | |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 195 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 58 |
Dominion Bridge Co. Ltd. v. The Queen, 75 DTC 5150, [1975] CTC 263, aff'd 77 DTC 5367, [1977] CTC 554 (FCA)
The amounts paid by a wholly-owned Bermudan subsidiary ("Span") for purchases of steel were found to constitute the taxpayer's cost of that steel,...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 105 | |
| Tax Topics - Income Tax Act - Section 9 - Related Companies | 105 |
Leon v. MNR, 76 DTC 6303, [1976] CTC 541 (FCA)
Fees paid by a company ("Ablan Leon Distributors") to a second company ("Nor-Mar") which was owned by its sole employee ("Leon") in respect of...
Simard-Beaudry Inc. v. M.N.R., 74 DTC 6552, [1974] CTC 715 (FCTD)
Before concluding (at p. 6557) that "the purchase by the Appellant by means of an option does not constitute a sham in the legal sense," and after...
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| Tax Topics - General Concepts - Agency | agent can act for two principals | 51 |
| Tax Topics - General Concepts - Sham | motives should not be exaggerated | 98 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | cost of option included in cost of acquired asset | 28 |
| Tax Topics - Income Tax Act - Section 245 - Old | 134 |
The Queen v. Kuhl, 74 DTC 6024, [1973] CTC 846 (FCTD)
"The company is not an agent of the owners."
See Also
The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue and Customs, [2019] EWCA Civ 93
Three “Scottish Trusts” exercised their put to sell shares of a listed public company to trusts (the “Irish Trusts”) with similar terms...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) | identifying the form of ultimate sale was not essential to finding a pre-ordained series | 516 |
Alberta v ENMAX Energy Corporation, 2018 ABCA 147
A parent of a municipal entity is not entitled to gain an advantage over its private competitors by arranging its subsidiaries’ affairs in a way...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest on a loan from a tax-exempt parent should be at an arm’s length rate reflecting implicit parental credit support | 494 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | arm’s length interest rate to sub could not be manipulated by structuring the loan as a junk bond without implicit parental credit support | 293 |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | purpose inferred in part from Legislative Assembly statement of Minister | 83 |
| Tax Topics - Income Tax Act - Section 67 | test of whether the amount was objectively reasonable | 293 |
McLarty v. The Queen, 2014 DTC 1162 [at 3556], 2014 TCC 30
The taxpayer, as a member of a joint venture, bought an undivided interest in seismic data for $20,000 cash and an $85,000 limited-recourse...
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| Tax Topics - General Concepts - Agency | participations contrary to agreement were disregarded | 111 |
| Tax Topics - General Concepts - Illegality | participations contrary to agreement were disregarded | 113 |
| Tax Topics - General Concepts - Sham | sham cannot apply to just part of transaction | 145 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | revenues 10% of interest | 186 |
| Tax Topics - Income Tax Act - Section 67 | leveraged purchase of seismic data at arm's length was presumptively reasonable | 296 |
Foresbec Inc. v. The Queen, 2002 DTC 1786 (TCC), aff'd 2003 DTC 5455, 2002 FCA 186
A consulting contract did not reflect the legal reality of the parties' rights and obligations (it was never contemplated that consulting services...
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|---|---|---|
| Tax Topics - General Concepts - Sham | documents did not reflect legal reality | 58 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 97 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 81 |
Lloyd v. The Queen, 2002 DTC 1493 (TCC)
Although the taxpayer signed an agreement with a holding company for the sale of shares in a company ("READ") to the holding company, Bowman...
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|---|---|---|
| Tax Topics - General Concepts - Effective Date | taxpayer can attack own transaction as legally ineffective | 138 |
| Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(1) | 76 | |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 - Paragraph 1(q) | 70 |
Thibault v. The Queen, 99 DTC 489 (TCC)
In addition to selling his shares of a company for $100,000, it was agreed that the company would hire a corporation controlled by the taxpayer as...
Eli Lilly & Co. v. Novopharm Ltd. (1998), 161 DLR (4th) 1, [1998] 2 S.C.R. 129
In discussing E.I. De Pont De Nemours & Co. v. Shell Oil Co., 227 U.S.P.Q. 223 (1985), Iacobucci J. stated (at p. 34) that in that case:
"the...
Giguère v. MNR, 93 DTC 488 (TCC)
The taxpayer was unsuccessful in his contention that although a contract for providing services to Télé - Métropole Inc. was with himself...
Keewatin Tribal Council Inc. v. City of Thompson, [1989] 2 CTC 206 (Man QB)
After noting that it was likely that the only reason for the creation of a trust for an Indian band was the avoidance of municipal taxation,...
Kosmopoulos v. Constitution Insurance Co., 34 DLR (4th) 208, [1987] 1 S.C.R. 2
The corporate veil can only be lifted where enforcement of the separate entities principle would yield a result flagrantly opposed to justice,...
Administrative Policy
9 November 2001 External T.I. 2001-0092495 - CTF ROUND TABLE-PROFESSIONAL CORPs
Notwithstanding the Wallsten decision, the CCRA will not accept that insurance agents or realtors can transfer their commission income to a...
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|---|---|---|
| Tax Topics - General Concepts - Illegality | 37 |
11 October 1991 T.I. (Tax Window, No. 11, p. 17, ¶1523)
Where members of a farming partnership transfer a herd of cattle to a corporation utilizing the s. 85(2) election and have the corporation...
81 C.R. - Q.9
The Daly case was decided on very narrow legal grounds because of deficiencies in the taxpayer's documentation.
Articles
John Tiley, "Tax Avoidance Jurisprudence as Normal Law", British Tax Review, 2004 No. 4, p. 304.
Sawyer, "Blurring Distinction between Avoidance and Evasion - The Abuse of Tax Position", 1996 British Tax Review, No. 5, p. 483.
David A. Ward, "Judicial Responses to Tax Avoidance", European Taxation, January 1995, p. 1.
Thivierge, "Emerging Income Tax Issues: Substance Over Form Revisited, Section 160 of the Income Tax Act, and Series of Transactions", 1993 Conference Report, c. 4
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|---|---|---|
| Tax Topics - General Concepts - Substance | 0 | |
| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | 0 |