In C.A.E. Inc. v. The Queen, 2013 FCA 92, the Federal Court of Appeal (FCA) sets the Tax Court of Canada (TCC) straight on some fundamentally important tax principles: the interplay between inventory and depreciable property. The facts provide…
In Imperial Tobacco Canada Limited v. The Queen, 2013 TCC 135, the Tax Court of Canada (TCC) usefully examined various elements of solicitor-client privilege and common interest privilege when it ordered the disclosure of certain documents. The judgment arose…
In 2013-0474111I7, the Rulings Division advised a local Tax Services Office that an acquired company could not reverse prior-year CCA claims so as to revive expired losses. The facts indicated that in taxation years before the company was acquired,…
In 2012-0468931C6, the CRA confirmed that the date of disposition for shares sold on a stock exchange is the “settlement date”. When shares are sold on a stock exchange, typically the settlement date is two or three days after…
The following blog was co-written by Greg DelBigio and Leah Plumridge:
The Canada Revenue Agency (“CRA”) now has easier access to confidential taxpayer records as a result of a recent British Columbia Supreme Court decision, Canada Revenue Agency v.…
The following blog was joint collaboration by Greg DelBigio, David Thompson, James Murdoch, and Steve Cook:
Last week saw tax law become the subject of international headlines. Media outlets excitedly announced that as a result of a “leak” of documents the…
“The Government will monitor developments in this area and, if structures or transactions emerge that undermine the effectiveness of the measure, evaluate whether further action is warranted, with possible retrospective application.” (My emphasis.)
“The Government will…
In 2012-0455081I7, the Canada Revenue Agency (CRA) considered costs of constructing a commercial building in circumstances where the land was owned by one company in a corporate group (A Co) and leased to another company in the group (B…
In 2012-0443471E5, the Canada Revenue Agency (CRA) confirmed its position that so-called “tracking shares” are “taxable preferred shares”. The term “tracking shares” (as well as “alphabet shares” and “targeted shares”) has typically been used to describe a special class…
In 2012-0449371I7, the Canada Revenue Agency (CRA) confirmed that a both an upstream and a downstream absorptive merger under US corporate law would qualify for tax-deferred (rollover) treatment under proposed new s. 87(8.2). The facts involved a Canadian company…