Corporate Tax | GetTaxNetPro

Abeilles Service de Conditionnement Inc. v. R. - TCC: Research on dryer sub-assembly was SRED

Jun 30, 2015 By Bill Innes

Précis: At issue in this appeal were four research projects in respect of which CRA had denied SRED credits. Three of the projects concerned the partial sub-assembly by the appellant for Mabe (a company 49% owned by General Electric) of dryers for sale by General Electric.
Abeilles Service de Conditionnement Inc. v. R. - TCC: Research on dryer sub-assembly was SREDREAD MORE »

Kruger Inc. v. R. - TCC: Only “financial institutions” can mark foreign exchange options to market

Jun 23, 2015 By Bill Innes

Précis: Because of its exposure to currency risk in multiple jurisdictions Kruger Incorporated (“Kruger”) started an aggressive risk management program using foreign exchange options. The program expanded to the point that they had a foreign exchange desk in house similar to that found in mainstream investment houses.
Kruger Inc. v. R. - TCC: Only “financial institutions” can mark foreign exchange options to marketREAD MORE »

Superior Plus v. R. - TCC: Crown ordered to produce extensive material underlying GAAR assessment

Jun 22, 2015 By Bill Innes

Précis: This is an example of procedural sparring in a large GAAR case where the taxpayer clearly emerged the victor at least in the initial stages in the Tax Court. The underlying transaction was the conversion of an income trust to a corporation, a conversion that was facilitated by amendments to the Income Tax Act several years ago:
Superior Plus v. R. - TCC: Crown ordered to produce extensive material underlying GAAR assessmentREAD MORE »

Inflection Analytics Ltd. v. R. - TCC: Fees to access data by internet not SRED expenses

Jun 12, 2015 By Bill Innes

Précis: The appellant was endeavouring to develop investment management software.
Inflection Analytics Ltd. v. R. - TCC: Fees to access data by internet not SRED expensesREAD MORE »

Hypercube Inc. v. R. - TCC: Program used for web site analysis not SRED

Jun 09, 2015 By Bill Innes

Précis: Hypercube Inc. claimed SRED expenses of $28,800 for the development of a program used to analyze web sites to find weaknesses and optimize performance. The Court rejected the claim on the basis that the work done was all based on existing technology and did not go beyond routine engineering and standard procedures.
Hypercube Inc. v. R. - TCC: Program used for web site analysis not SREDREAD MORE »

Kinglon Investments Inc. v. R. - FCA: CRA need not plead person for whom tax shelter representations made

Jun 03, 2015 By Bill Innes

Précis: This case involved what the Crown alleged to be an unregistered tax shelter. Part of the Crown’s Reply dealt with statements allegedly made concerning the tax shelter.
Kinglon Investments Inc. v. R. - FCA: CRA need not plead person for whom tax shelter representations madeREAD MORE »

R. v. Caisse Desjardin de Québec – FCA: Requirement to pay served on bank of insolvent customer not effective

Apr 20, 2015 By Bill Innes

Précis: A requirement to pay was served on the Caisse Desjardin in connection with one of its customers. Although the customer had money in its account when the requirement was received it was also indebted to the Caisse on a variable credit contract; the Caisse applied the money in the account to that debt rather than paying it in accordance with the requirement.
R. v. Caisse Desjardin de Québec – FCA: Requirement to pay served on bank of insolvent customer not effectiveREAD MORE »

Nanica Holdings Limited v. R. – TCC: Dividend refunds need to be paid in order to erode a corporation’s RDTOH balance

Apr 20, 2015 By Bill Innes

Précis: The taxpayer claimed dividend refunds in 2011 and 2012 which were partially denied by CRA. The denial was based on the fact that the taxpayer would have been entitled to dividend refunds in 2007 and 2008 had it filed its tax returns on time, but the returns were in fact filed outside the three year limitation period established by subsection 129(1) of the Income Tax Act.
Nanica Holdings Limited v. R. – TCC: Dividend refunds need to be paid in order to erode a corporation’s RDTOH balanceREAD MORE »

6379249 Canada Inc. v. R. – TCC: Miniature wireless printer development costs qualified as SRED

Apr 09, 2015 By Bill Innes

6379249 Canada Inc. v. R. – TCC: Miniature wireless printer development costs qualified as SREDREAD MORE »

Zeldap Corporation v. R. – TCC: No litigation privilege – taxpayer compelled to answer question on discovery

Apr 09, 2015 By Bill Innes

Zeldap Corporation v. R. – TCC: No litigation privilege – taxpayer compelled to answer question on discoveryREAD MORE »

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