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Sun Life Assurance v. R. - TCC: Taxpayer awarded costs of $91,792 after date of offer to settle
Jul 23, 2015 By Bill Innes
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Précis: The taxpayer had made a settlement offer in this decision which was more favourable to the Crown than the ultimate award made by the Court. The taxpayer asked for a lump sum costs award of $200,000 including hourly rates, disbursements and taxes. The Court awarded costs of $91,782, plus disbursements and appropriate HST
Sun Life Assurance v. R. - TCC: Taxpayer awarded costs of $91,792 after date of offer to settleREAD MORE »
Cameco v. R. - FCA: Interlocutory appeal allowed in part, no costs in FCA or TCC
Jul 23, 2015 By Bill Innes
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Précis: The taxpayer moved unsuccessfully before the Tax Court to strike portions of the Crown’s reply in a uranium transfer pricing case. The Tax Court ordered solicitor-client costs against the taxpayer. The taxpayer appealed to the Federal Court of Appeal.
Cameco v. R. - FCA: Interlocutory appeal allowed in part, no costs in FCA or TCCREAD MORE »
Repsol Canada Ltd. v. R. - TCC: Court slams the Crown with $561,693.00 costs award
Jul 22, 2015 By Bill Innes
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Précis: The taxpayer was completely successful in a decision blogged earlier on this site and had made a settlement offer which the Crown had refused (and which was more favourable to the Crown than the ultimate result):
Repsol Canada Ltd. v. R. - TCC: Court slams the Crown with $561,693.00 costs awardREAD MORE »
1455257 Ontario Inc. - v. R. - TCC: Dissolved corporation ordered to obtain revival to continue appeal
Jul 20, 2015 By Bill Innes
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Précis: The taxpayer was an Ontario corporation that was dissolved in 2007. On October 18, 2010, it was assessed pursuant to section 160 of the Income Tax Act (the “Act”) relating to the tax indebtedness of 1473661 Ontario Limited (presumably a related corporation) as at that date. The Crown moved to compel the taxpayer to take steps to revive its corporate status within 30 days.
1455257 Ontario Inc. - v. R. - TCC: Dissolved corporation ordered to obtain revival to continue appealREAD MORE »
Hill Fai Inv. v. R. - TCC: Inadequate evidence to demonstrate bad debt of $382,219.31 in 2006
Jul 17, 2015 By Bill Innes
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Précis: The taxpayer claimed to have incurred a capital loss on a bad debt of $382,219.31 in its taxation year ended September 30, 2006. The loss in turn impacted on its taxation years ended September 30 in each of 2005, 2007 and 2008.
Hill Fai Inv. v. R. - TCC: Inadequate evidence to demonstrate bad debt of $382,219.31 in 2006READ MORE »
GMAC Leaseco v. R. - TCC: $235 million “support payments” from GM taxable
Jul 10, 2015 By Bill Innes
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Précis: This decision involves four sources of income which were assessed by CRA against GMAC Leasco (“GMAC”) [para. 2 of the Reasons].
GMAC Leaseco v. R. - TCC: $235 million “support payments” from GM taxableREAD MORE »
Coombs v. R. - TCC: Tax Court rejects alleged losses
Jul 08, 2015 By Bill Innes
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Coombs v. R. - TCC: Tax Court rejects alleged lossesREAD MORE »
Highweb & Page Group Inc. v. R. - TCC: No SRED credits for badly documented work
Jul 03, 2015 By Bill Innes
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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 workREAD MORE »
Standard Life v. R. - TCC: Crown awarded a staggering $474,663 in costs
Jul 03, 2015 By Bill Innes
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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 costsREAD MORE »
Deans Knight Income Corporation v. R. - TCC: Motion to strike Reply in GAAR case dismissed
Jul 02, 2015 By Bill Innes
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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 dismissedREAD MORE »