refund

984274 Alberta Inc. v. The Queen, 2019 TCC 85, rev'd 2020 FCA 125 -- summary under Subsection 160.1(1)

Full Title
984274 Alberta Inc. v. The Queen, 2019 TCC 85, rev'd 2020 FCA 125
Summary Under
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

The taxpayer (“984”) reported a capital gain on its 2003 sale of land on the basis that it had acquired it from its parent (Henro) on a...

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Words and Phrases
refund
overpayment

Presidential MSH Corporation v. The Queen, 2015 DTC 1101 [at pp. 596-610], 2015 TCC 61 -- summary under Subsection 129(1)

Full Title
Presidential MSH Corporation v. The Queen, 2015 DTC 1101 [at pp. 596-610], 2015 TCC 61
Summary Under
Tax Topics - Income Tax Act - Section 129 - Subsection 129(1)
RDTOH not reduced by unclaimed dividend refunds

The taxpayer paid taxable dividends in its 2005 to 2006 taxation years but missed the three-year deadline to apply for dividend refunds. Graham J...

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refund

Tawa Developments Inc. v. The Queen, 2011 DTC 1324 [at at 1837], 2011 TCC 440 -- summary under Subsection 129(3)

Full Title
Tawa Developments Inc. v. The Queen, 2011 DTC 1324 [at at 1837], 2011 TCC 440
Summary Under
Tax Topics - Income Tax Act - Section 129 - Subsection 129(3)
refundable dividend tax on hand not extinguished by three-year limitations period on dividend refund

The taxpayer failed to apply for its dividend refund for a taxation year within the three year time-limit, and its dividend refund that year was...

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refund

Canada Safeway Ltd. v. R., 98 DTC 6060, [1998] 1 CTC 120 (FCA) -- summary under Subparagraph 12(1)(x)(iv)

Full Title
Canada Safeway Ltd. v. R., 98 DTC 6060, [1998] 1 CTC 120 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv)
sales tax refund not reimbursement

In finding that a refund of federal sales tax that predecessors of the taxpayer previously had paid in error did not qualify as a reimbursement...

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Words and Phrases
refund
reimbursement
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