In Daishowa-Marubeni International Ltd. v. The Queen, 2013 SCC 29, the Supreme Court of Canada unanimously decided that reforestation obligations – assumed by a purchaser of a forest tenure in Alberta – represented a future expense embedded in the…
In 2013-0477601E5, the CRA was asked “why in the Singleton case the interest deduction was allowed whereas in the Lipson case the deduction was not allowed”. The CRA responded that in Lipson v. The Queen the Supreme Court of…
In Morguard Corporation v. The Queen, the Federal Court of Appeal (FCA) upheld a Tax Court decision that a “break fee” received by a parent company (in a corporate group) in the course of its attempted acquisition of a target…
In Macdonald v. The Queen, 2013 FCA 110, the Federal Court of Appeal (FCA) held that corporate funds were distributed to a sole shareholder “in any manner whatever” on the winding up of the corporation’s business, with the result…
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…
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…