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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 »
Abeilles Service de Conditionnement Inc. v. R. - TCC: Research on dryer sub-assembly was SRED
Jun 30, 2015 By Bill Innes
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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 »
Watts v. R. - FCA: No appeal of 2007 taxation year - matter res judicata
Jun 25, 2015 By Bill Innes
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Précis: The taxpayer filed a Notice of Appeal dated January 9, 2012 of his 2007 taxation year. The matter was heard before Campbell J. of the Tax Court who struck the appeal.
Watts v. R. - FCA: No appeal of 2007 taxation year - matter res judicataREAD MORE »
Kruger Inc. v. R. - TCC: Only “financial institutions” can mark foreign exchange options to market
Jun 23, 2015 By Bill Innes
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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
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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 »