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

Jul 06, 2015 By Bill Innes

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 taxableREAD MORE »

Highweb & Page Group Inc. v. R. - TCC: No SRED credits for badly documented work

Jul 03, 2015 By Bill Innes

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

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

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

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 »

De Santis v. R. - TCC: Court rejects CRA’s reduction (factor of 3.2) in the value of donated wine

Jun 29, 2015 By Bill Innes

Précis: Mr. DeSantis made donations of rare wine to a Gatineau charity in each of 2009, 2010 and 2011. The wines were valued in each case by Alain Laliberté, a wine appraiser and sommelier with a degree from the Faculté d’œnologie de Bordeaux.
De Santis v. R. - TCC: Court rejects CRA’s reduction (factor of 3.2) in the value of donated wineREAD MORE »

Gordon Feil, C.G.A. Ltd. v. R. - TCC: Payments to “corporation sole” a mere conduit to tax debtor

Jun 26, 2015 By Bill Innes

Précis: Gordon Feil, C.G.A. Ltd and Leslie Feil, C.G.A. Ltd., carried on a joint venture as Feil & Co. Gordon and Leslie Feil were brothers. Each corporation received requirement to pay in respect of Gordon Feil in respect of a tax debt of $93,645.
Gordon Feil, C.G.A. Ltd. v. R. - TCC: Payments to “corporation sole” a mere conduit to tax debtorREAD MORE »

Mosly v. R. - TCC: Taxpayer embezzled amounts in 1999, alleged thefts in 2003 and 2004 not proven

Jun 25, 2015 By Bill Innes

Précis: Mr. Mosly was assessed for 1999 for $460,000 stolen from a business client. The Court did not accept his explanations and dismissed his appeal. He was also assessed for 2003 and 2004 in respect of amounts he allegedly embezzled from two companies of which he was a 50% shareholder along with a former friend with whom he became involved in messy litigation.
Mosly v. R. - TCC: Taxpayer embezzled amounts in 1999, alleged thefts in 2003 and 2004 not provenREAD MORE »

Watts v. R. - FCA: No appeal of 2007 taxation year - matter <i>res judicata</i>

Watts v. R. - FCA: No appeal of 2007 taxation year - matter res judicata

Jun 25, 2015 By Bill Innes

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

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 »

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