On July 10, 2012, the Tax Court of Canada (the “TCC”) released its judgment in Dickie v. The Queen (2012 TCC 242) wherein Miller Thomson was successful in having a reassessment under the Income Tax Act (Canada) (the “Act”) vacated. ...
The Tax Court of Canada (the “TCC”) considered the tax treatment of break fees in Morguard Corporation v. The Queen (2012 TCC 550) (“Morguard”) for purposes of the Income Tax Act (Canada) (the “Act”) from the recipient’s perspective. The taxpayer...
In Velcro Canada Inc. v. Her Majesty the Queen (2012 TCC 57), the Tax Court of Canada (the “TCC”) applied the test of beneficial ownership as established by the Federal Court of Appeal in Prévost Car Inc. v. Canada (2009...
In the recent case of Price Waterhouse Coopers Inc. Agissant Ès Qualité de Syndic à la Faillite de Bioartificial Gel Technologies (Bagtech) Inc. v. The Queen (2012 CCI 120) (“Bagtech”), the Tax Court of Canada (the “TCC”) ruled that Bagtech...
The recent decision of the Tax Court of Canada (the “TCC”) in Twomey v. Her Majesty the Queen (2012 TCC 310) highlights the importance of strict compliance with the technical provisions of the Income Tax Act (Canada) (the “Act”), as...
