Archives - juillet 2015

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  Ghaffari v. R. - TCC: Unreported rental income of $100,000 taxable

  6 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Personal Tax, Estate & Wealth Planning

  Précis: This case involved the appeal of spouses, Shahrzad Ghaffari and Bernard Tajick, against an inclusion in their incomes for 2009 by the Minister of $50,550 each. They were co-owners of a building located at 3130 Sainte Catherine Street East, Montréal which was operated by a general partnership owned by them (“Best Dev”) and leased to a corporation owned by them (“Auberge”).
  Ghaffari v. R. - TCC: Unreported rental income of $100,000 taxablePlus >
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  Tax Court of Canada Appointment: Justice Guy R. Smith

  6 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Other

  The Honourable Peter MacKay, P.C., Q.C., M.P. for Central Nova, Minister of Justice and Attorney General of Canada, today announced the following appointment...
  Tax Court of Canada Appointment: Justice Guy R. SmithPlus >
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  Standard Life v. R. - TCC: Crown awarded a staggering $474,663 in costs

  3 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: This is the costs decision in the Standard Life appeal. The Crown asked for costs at a rate of 50% of solicitor and client costs up to the date of a written settlement offer and 80% thereafter, plus reasonable disbursements.
  Standard Life v. R. - TCC: Crown awarded a staggering $474,663 in costsPlus >
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  Highweb & Page Group Inc. v. R. - TCC: No SRED credits for badly documented work

  3 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: The appellant was in the business of marketing and design of digital software and web-based accessibility systems. The dispute concerned SRED expenditures in its 2007 and 2008 taxation years. The Minister denied the bulk of these claims.
  Highweb & Page Group Inc. v. R. - TCC: No SRED credits for badly documented workPlus >
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  Roberts v. R. - TCC: Telemarketer was not an employee

  2 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Employment Insurance/CPP

  Mr. Roberts worked as a telemarketer of insurance industry products for Michael Libourkine. He claimed that he was engaged in insurable employment for EI purposes. The Minister determined otherwise and Mr. Roberts appealed.
  Roberts v. R. - TCC: Telemarketer was not an employeePlus >
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  Deans Knight Income Corporation v. R. - TCC: Motion to strike Reply in GAAR case dismissed

  2 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: In it taxation years ending December 31, 2009 to 2012 the appellant claimed non-capital losses, a terminal loss and SRED expenditure (the “Claimed Amounts”). These arose of out transactions the appellant had entered into in 2008 and 2009 and related to periods prior to those transactions.
  Deans Knight Income Corporation v. R. - TCC: Motion to strike Reply in GAAR case dismissedPlus >
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  Federal Court of Appeal Appointments: Justice Yves de Montigny and Justice Mary J.L. Gleason

  2 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Other

  The Honourable Peter MacKay, P.C., Q.C., M.P. for Central Nova, Minister of Justice and Attorney General of Canada, today announced the following appointments...
  Federal Court of Appeal Appointments: Justice Yves de Montigny and Justice Mary J.L. GleasonPlus >
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  Federal Court Appointments: Justice Robin Camp, Justice E. Susan Elliott, Justice Sylvie Roussel, Justice Ann Marie McDonald

  2 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Other

  The Honourable Peter MacKay, P.C., Q.C., M.P. for Central Nova, Minister of Justice and Attorney General of Canada, today announced the following appointments...
  Federal Court Appointments: Justice Robin Camp, Justice E. Susan Elliott, Justice Sylvie Roussel, Justice Ann Marie McDonaldPlus >
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  Fairmont Hotels v. R. - OCA: Courts broaden basis for granting rectification in tax cases

  2 juillet 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Other

  Précis: In Fairmont Hotels Inc v Attorney General of Canada, the Ontario Court of Appeal upheld the application judge’s granting of the equitable remedy of rectification to a taxpayer whose intention to achieve a particular tax result was mistakenly implemented.
  Fairmont Hotels v. R. - OCA: Courts broaden basis for granting rectification in tax casesPlus >