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Appeal court orders retrial on Heron Bay
- Borden Ladner Gervais LLP
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- Canada
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- August 9 2010
In a judgment in Heron Bay Investments Ltd. v. The Queen (2010 FCA 203), delivered on July 26, 2010, the Canadian Federal Court of Appeal found that there was a “want of procedural fairness” in the proceedings of the Tax Court which resulted in its decision of September 8, 2009 (2009 TCC 337) and, as requested by the appellant, Heron Bay, in its pleadings, returned the matter to the Tax Court “for retrial by a different judge”
Court of appeal accepts GlaxoSmithKline arguments in transfer pricing case
- Borden Ladner Gervais LLP
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- Canada
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- July 29 2010
On July 26, 2010, the Canadian Federal Court of Appeal released its decision in the case of GlaxoSmithKline Inc
U.S. LLCs should consider refund claims for branch tax paid to Canada
- Borden Ladner Gervais LLP
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- Canada, USA
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- July 22 2010
On April 8, 2010, the Tax Court of Canada found in favour of the taxpayer in TD Securities (USA) LLC v. The Queen
Crown appeals General Electric case
- Borden Ladner Gervais LLP
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- Canada
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- March 18 2010
On January 4, 2010, the Crown deposited with the Federal Court of Appeal its notice of appeal of the Tax Court of Canada's judgment in the case of General Electric Capital Canada Inc
Canada’s Supreme Court to hear GAAR appeal
- Borden Ladner Gervais LLP
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- Canada
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- February 9 2010
The concept of paid-up capital is important for Canadian tax purposes in that, unlike certain of its treaty partners, Canada permits corporations to return capital to shareholders (even if they have accumulated earnings and profits for tax purposes), without payment of Canadian non-resident withholding tax
Crown appeals General Electric decision
- Borden Ladner Gervais LLP
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- Canada
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- January 7 2010
On January 4, 2010, the Crown filed with the Federal Court of Appeal its Notice of Appeal of the Tax Court of Canada’s judgment (issued on December 4, 2009) in the case of General Electric Capital Canada Inc. v. The Queen
Barbados trust cannot side-step normal tax appeal process
- Borden Ladner Gervais LLP
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- Canada
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- January 6 2010
In Canada (National Revenue) v. Morris, the Minister of National Revenue appealed a Federal Court judgment requiring it to provide the RCI Trust, a Barbados settled trust, with a written decision on whether shares sold by the trust in 2006 were treaty exempt property under the Canada-Barbados Income Tax Convention
Arm’s length principle interpreted by Canadian court
- Borden Ladner Gervais LLP
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- Canada
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- December 8 2009
On December 4, 2009, the long awaited decision in General Electric Capital Canada Inc. v. The Queen was released by Canada's Tax Court
Money lender’s doubtful and bad debt claims on “extraordinary” loan disallowed
- Borden Ladner Gervais LLP
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- Canada
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- November 30 2009
In Heron Bay Investments Ltd. v. The Queen, the Tax Court considered whether a $3.77 million non-recourse demand loan made in 1994 by Heron Bay to another corporate group member met the criteria for deductibility under the Income Tax Act (Canada) as either a doubtful debt or a bad debt in Heron Bay’s 1995 taxation year
Barbados spousal trust strategy fails Canadian trust and GAAR tests
- Borden Ladner Gervais LLP
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- Canada
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- October 7 2009
In Paul Antle and Renee Marquis-Antle Spousal Trust v. The Queen, the Tax Court considered a series of transactions implemented by a Canadian resident taxpayer known as a “capital property step-up strategy”
Current Search
- Jurisdiction - Canada
- Workarea - Litigation
- Workarea - Corporate Tax
- Author - Elinore J. Richardson
- Firm Name - Borden Ladner Gervais LLP