The factual basis for this case is somewhat complex technically ... Notwithstanding that complexity the question boiled down to whether the advance of $528,560.00 from SDTC was taxable in 2014, notwithstanding that it was paid in trust to the Appellant.
Justice Campbell concluded that the degree of control exercised by the Appellant over the advance from SDTC was sufficient to bring the advance into income in 2014. As a result the appeal was dismissed. There was no order as to costs since this was an informal procedure appeal.
Borealis Geopower Inc. v. R. – TCC: SRED grant paid to trust account in 2014 was taxable income in 2014READ MORE »