Section 169

Table of Contents

Section 169
Cases(9)
See Also(16)
Administrative Policy(3)
Subsection 169(1) - Appeal
Cases(10)
See Also(17)
Administrative Policy(1)
Subsection 169(2.1) - Limitation on appeals by large corporations
Cases(3)
See Also(5)
Subsection 169(2.2) - Waived issues
Cases(1)
See Also(3)
Administrative Policy(1)
Subsection 169(3) - Disposition of appeal on consent
Cases(2)
See Also(5)
169(4)
See Also(1)

Cases

Canada (National Revenue) v. ConocoPhillips Canada Resources Corp., 2014 FCA 297, rev'g 2013 FC 1192

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Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.5 appeal to Tax Court required for decision of CRA to treat a Notice of Objection as invalid 218

Conocophillips Canada Resources Corp. v. Canada (National Revenue), 2014 DTC 5014 [at 6598], 2013 FC 1192, rev'd supra

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Clearwater Seafoods Holding Trust v. Canada, 2013 DTC 5132 [at 6218], 2013 FCA 180

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460354 Ontario Inc. v. The Queen, 92 DTC 6534 (FCTD)

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Attorney General of Canada v. Bowen, 91 DTC 5594 (FCA)

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Nova Ban-Corp Ltd. v. Tottrup, 89 DTC 5489 (FCTD)

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Mackay Construction Ltd. v. The Queen, 89 DTC 5097 (FCTD)

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The Queen v. Gary Bowl Ltd., 74 DTC 6401, [1974] C.T.C 457 (FCA)

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Okalta Oils Ltd. v. Minister of National Revenue, 55 DTC 1176, [1955] CTC 271, [1955] S.C.R. 824

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Words and Phrases
assessment

See Also

Davis v. The Queen, 2015 DTC 1105 [at 621], 2015 TCC 79 (Informal Procedure)

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Nottawasaga Inn Ltd. v. The Queen, 2014 DTC 1021 [at 2628], 2013 TCC 377 (Informal Procedure)

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Words and Phrases
nil assessment

SoftSim Technologies Inc. v. The Queen, 2012 DTC 1187 [at 3473], 2012 TCC 181

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Mcfadyen v. The Queen, 2008 DTC 4513, 2008 TCC 441

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Tax Topics - General Concepts - Res Judicata 140

Graham v. The Queen, 92 DTC 1012 (TCC)

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Hill v. MNR, 91 DTC 1094 (TCC)

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Lornport Investments Ltd. v. The Queen, 91 DTC 5044 (FCTD)

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Bowen v. MNR, 90 DTC 1625 (TCC)

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Lornex Mining Corp. Ltd. v. MNR, 88 DTC 6399, [1988] 2 CTC 195 (FCTD)

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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) 36

The Queen v. Bowater Mersey Paper Co. Ltd., 87 DTC 5382, [1987] 2 CTC 159 (FCA)

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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) 129

Gibbs v. MNR, 84 D.TC. 6418, [1984] CTC 434 (FCTD)

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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) 37

MNR v. Parsons and Flemming, 84 DTC 6345, [1984] CTC 352 (FCA)

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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) 48

Millers Credit Jewellers Ltd. v. The Queen, 84 DTC 6205, [1984] CTC 218 (FCTD)

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Midwest Oil Production Ltd. v. The Queen, 82 DTC 6092, [1982] CTC 107 (FCTD), aff'd 83 DTC 5304, [1983] CTC 338 (FCA)

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MacIsaac v. The Queen, 83 DTC 5258, [1983] CTC 213 (FCTD)

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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) 86

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

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Administrative Policy

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 8

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Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1) time stamping of items received 91

S4-F7-C1 - Amalgamations of Canadian Corporations

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Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 103
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 155
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 126
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 145
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 82
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 164
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) related party, majority and 50% group exceptions 448
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 103
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 104
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 159
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 81
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 60
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 114
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 47
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 260
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 700
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 135
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 133
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 96
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 159
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 38
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 328
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 181
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 247
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 171
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 218
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 106
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 56
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 123
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 415
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 323
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 311
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 96
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3) 127
Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) 170

91 C.R. - Q.66

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Subsection 169(1) - Appeal

Cases

1455257 Ontario Inc. v. Canada, 2016 FCA 100

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Tax Topics - Other Legislation/Constitution - Ontario - Business Corporations Act - Section 242 dissolved corporation cannot launch appeal/voluntarily dissolved corp cannot be revived by Companie Branch 248
Tax Topics - General Concepts - Stare Decisis prior decisons overruled only if manifestly wrong 75

Canada v. Doiron, 2012 DTC 5103 [at 7081], 2012 FCA 71

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Canada v. Quigley, 2009 DTC 6206, 2009 FCA 287

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Canada v. General Motors of Canada Limited, [2009] GSTC 64, 2009 FCA 114

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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) services for pension plans represented compensation costs relating to taxable sales 129

Canada v. Interior Savings Credit Union, 2007 DTC 5342, 2007 FCA 151

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Bormann v. Canada, 2006 DTC 6147, 2006 FCA 83

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398722 Alberta Ltd. v. Canada, [2000] FCJ No. 644 (CA)

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MNR v. Minden, 62 DTC 1044 (Ex Ct)

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Cole v. Canada (Attorney General), 2005 DTC 5667, 2005 FC 1445

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Transcanada Pipelines Ltd. v. The Queen, 2001 DTC 5626, 2001 FCA 314

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See Also

Lilyfield Development Inc. v. The Queen, 2020 TCC 16

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Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Act - Section 21 appeal is not launched until Notice of Appeal is filed 200

102751 Canada Inc. v. Agence du revenu du Québec, 2019 QCCQ 7378

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages legal fees incurred to recover misappropriated funds were not capital expenditures 345

Pietrovito v. The Queen, 2017 TCC 119

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Tax Topics - Income Tax Act - Section 167 - Subsection 167(5) - Paragraph 167(5)(a) time period not suspended where taxpayer reasonably believed appeal had been filed 331
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 54 failure to appeal 2nd taxation year not curable through amendment 73

Shreedhar v. The Queen, 2016 TCC 254 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) assessment of nil tax and $2 of interest could be objected to 126

Beggs v. The Queen, 2016 TCC 11 (Informal Procedure)

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Words and Phrases
assessment
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) refusal to grant Reg. 105 waiver not an assessment/remedy in FC 66

Izumi v. The Queen, 2014 DTC 1114 [at 3254], 2014 TCC 108

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Pylatuke v. The Queen, 2014 DTC 1019 [at 2620], 2013 TCC 364

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Cameco Corporation v. The Queen, 2014 TCC 45

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Tax Topics - General Concepts - Evidence proportionality principle 182
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege basis for claim not disclosed 113

Clearwater Seafoods Holdings Trust v. The Queen, 2012 DTC 1177 [at 3447], 2012 TCC 186, rev'd supra

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McIntosh v. The Queen, 2011 DTC 1116 [at 625], 2011 TCC 147

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Uddin v. The Queen, 2009 DTC 1331, 2009 TCC 471 (Informal Procedure)

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Khan v. The Queen, 2009 DTC 804, 2009 TCC 248 (Informal Procedure)

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Tax Topics - General Concepts - Onus 39

Interior Savings Credit Union v. The Queen, 2006 DTC 3351, 2006 TCC 411

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Parent v. The Queen, 2003 DTC 1002, 2003 TCC 509

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Imperial Oil Ltd. v. The Queen, 2003 DTC 179, 2003 TCC 46, aff'd 2003 FCA 289

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Tax Topics - Statutory Interpretation - Ordinary Meaning 76

Wells v. The Queen, [2001] 4 CTC 2950 (TCC)

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Edwards v. Minister of Finance (Ontario), 99 DTC 5475 (Ont. C.T. (G.D.))

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Administrative Policy

3 June 2014 Internal T.I. 2013-0489471I7 - Subsection 171(1)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.3) no power to reassess following order to vacate or vary 99
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) no power to reassess following order to vacate or vary 99

Subsection 169(2.1) - Limitation on appeals by large corporations

Cases

Devon Canada Corporation v. Canada, 2015 FCA 214

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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.11) large corporations can appeal new issues which were rejected by CRA Appeals, and perhaps may raise new issues within 1 year of Objection 91

Bakorp Management Ltd. v. Canada, 2014 DTC 5063 [at 6870], 2014 FCA 104

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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.11) new timing argument raised on appeal 330

Canada v. Potash Corp. of Saskatchewan, 2004 DTC 6002, 2003 FCA 471

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See Also

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 393
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) investment dealer fees re advisability of making hostile takeover were fully deductible 515
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales 170
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 96
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations 343
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) failure to advance evidence showing allocation of fees to share consideration 131
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) expenses incurred in butterfly spin-off recognized as disposition expenses 61
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 102

Ford Motor Company of Canada Limited v. The Queen, 2015 TCC 39

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Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) issues raised in Objection were understandable in light of previous materials provided to CRA 268

Devon Canada Corporation v. The Queen, 2014 DTC 1192 [at 3727], 2014 TCC 255, rev'd 2015 FCA 214

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Canada v. Telus Communications (Edmonton) Inc., 2005 FCA 159

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Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) due diligence defence not raised 164

Newmont Canada Limited v. The Queen, 2005 DTC 617, 2005 TCC 143

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Subsection 169(2.2) - Waived issues

Cases

Abdalla v. Canada, 2019 FCA 5

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See Also

Savics v. The Queen, 2019 TCC 71

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Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) a settlement agreement referring to partnership loss allocations included partnership gains allocations 516

Abdalla v. The Queen, 2017 TCC 222 (Informal Procedure), aff'd 2019 FCA 5

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Words and Phrases
waiver

Taylor v. The Queen, 2010 DTC 1189 [at 3449], 2010 TCC 246

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Administrative Policy

AD-19-01 Audit Agreement and Waiver of Objection Rights Guidelines 2019-02-19

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 460

Subsection 169(3) - Disposition of appeal on consent

Cases

Canada v. CBS Canada Holdings Co., 2020 FCA 4

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Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) - Paragraph 171(1)(b) Tax Court order could contemplate increased taxes for 1 taxation year in implementing settlement agreement 227

University Hill Holdings Inc. (Formerly 589918 B.C. Ltd.) v. Canada, 2017 FCA 232

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) a settlement agreement agreeing as to round percentages of expenses that were unreasonable accorded with Galway 299

See Also

984274 Alberta Inc. v. The Queen, 2019 TCC 85

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii) reassessment made pursuant to late waiver was void 32
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) reassessment made pursuant to late waiver could not be cured by s. 152(8) 45
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) invalid reassessment could not establish a refund amount 259
Tax Topics - Income Tax Act - Section 160.1 - Subsection 160.1(1) refund made pursuant to a void reassessment was not made pursuant to the Act (and also was not a “refund” on ordinary principles) so that s. 160.1(1) unavailable 472

Savics v. The Queen, 2019 TCC 71

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Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.2) waiver does not preclude appeal where settlement agreement improperly implemented 235

CBS Canada Holdings Co. v. The Queen, 2018 TCC 188, aff'd 2020 FCA 4

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) settlement agreement was grounded in reality 125

Granofsky v. The Queen, 2016 TCC 181, aff'd 2017 FCA 119

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Bolton Steel Tube Co. Ltd. v. The Queen, 2014 DTC 1102 [at 3202], 2014 TCC 94

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Tax Topics - General Concepts - Evidence terms of agreement established with regard to "factual matrix" 110
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) reassessment to add fictitious income was void 312

169(4)

See Also

208539 Alberta Ltd v. The Queen, 2011 TCC 106 (Informal Procedure)

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