Section 21
Cases
Métaux Kitco Inc. v. ARQ and AG, 2016 QCCS 444
The appellant (“Kitco”), a gold refiner, went into protection under the CCAA, after the CRA and ARQ (the “Agencies”) reassessed it for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 318 | no set-off of assessment of pre-CCAA filing periods against post CCAA ITC claims | 115 |
| Tax Topics - Excise Tax Act - Section 299 - Subsection 299(3) | no presumption of validity in CCAA proceedings | 121 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | no presumed validity in CCAA proceedings | 89 |
Section 32
Subsection 32(7)
Cases
Agence du revenu du Québec v. FTI Consulting Canada Inc., 2022 QCCA 1740
The appellants (the “ARQ”) were owed approximately $13.4 million of tax by a corporation (“CQIM”) immediately before it was placed into...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 182 - Subsection 182(1) | an ITC claim arising under ETA s. 182 after a CCAA filing could not be set off by the ARQ against a pre-filing tax debt | 497 |
| Tax Topics - Statutory Interpretation - Similar Statutes/ in pari materia | CCAA not in pari materia with ETA provisions | 173 |