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Standard Life v. R. - TCC: Crown awarded a staggering $474,663 in costs
3 juillet 2015 By Bill Innes
catégories:
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 costsPlus >
Fairmont Hotels v. R. - OCA: Courts broaden basis for granting rectification in tax cases
2 juillet 2015 By Bill Innes
catégories:
- Bill Innes on Current Tax Cases
- Other
Précis: In Fairmont Hotels Inc v Attorney General of Canada, the Ontario Court of Appeal upheld the application judge’s granting of the equitable remedy of rectification to a taxpayer whose intention to achieve a particular tax result was mistakenly implemented.
Fairmont Hotels v. R. - OCA: Courts broaden basis for granting rectification in tax casesPlus >
Federal Court of Appeal Appointments: Justice Yves de Montigny and Justice Mary J.L. Gleason
2 juillet 2015 By Bill Innes
catégories:
- Bill Innes on Current Tax Cases
- Other
The Honourable Peter MacKay, P.C., Q.C., M.P. for Central Nova, Minister of Justice and Attorney General of Canada, today announced the following appointments...
Federal Court of Appeal Appointments: Justice Yves de Montigny and Justice Mary J.L. GleasonPlus >
Federal Court Appointments: Justice Robin Camp, Justice E. Susan Elliott, Justice Sylvie Roussel, Justice Ann Marie McDonald
2 juillet 2015 By Bill Innes
catégories:
- Bill Innes on Current Tax Cases
- Other
The Honourable Peter MacKay, P.C., Q.C., M.P. for Central Nova, Minister of Justice and Attorney General of Canada, today announced the following appointments...
Federal Court Appointments: Justice Robin Camp, Justice E. Susan Elliott, Justice Sylvie Roussel, Justice Ann Marie McDonaldPlus >
Roberts v. R. - TCC: Telemarketer was not an employee
2 juillet 2015 By Bill Innes
catégories:
- Bill Innes on Current Tax Cases
- Employment Insurance/CPP
Mr. Roberts worked as a telemarketer of insurance industry products for Michael Libourkine. He claimed that he was engaged in insurable employment for EI purposes. The Minister determined otherwise and Mr. Roberts appealed.
Roberts v. R. - TCC: Telemarketer was not an employeePlus >
Deans Knight Income Corporation v. R. - TCC: Motion to strike Reply in GAAR case dismissed
2 juillet 2015 By Bill Innes
catégories:
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 dismissedPlus >
Abeilles Service de Conditionnement Inc. v. R. - TCC: Research on dryer sub-assembly was SRED
30 juin 2015 By Bill Innes
catégories:
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 SREDPlus >
De Santis v. R. - TCC: Court rejects CRA’s reduction (factor of 3.2) in the value of donated wine
29 juin 2015 By Bill Innes
catégories:
- Bill Innes on Current Tax Cases
- Personal Tax, Estate & Wealth Planning
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 winePlus >
Union of Municipalities NB v. R. - FC: Revocation of GST “municipal” status reasonable
29 juin 2015 By Bill Innes
catégories:
- Bill Innes on Current Tax Cases
- Other
Précis: Effective July 1, 1997 the Union of Municipalities of New Brunswick (“UNMB”) was granted the status of a “municipality” for GST purposes. UMNB was an organization representing 59 of 105 municipalities of New Brunswick but provided no actual municipal functions.
Union of Municipalities NB v. R. - FC: Revocation of GST “municipal” status reasonablePlus >
Gordon Feil, C.G.A. Ltd. v. R. - TCC: Payments to “corporation sole” a mere conduit to tax debtor
26 juin 2015 By Bill Innes
catégories:
- Bill Innes on Current Tax Cases
- Personal Tax, Estate & Wealth Planning
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 debtorPlus >