Tags » Income Tax Act

Odebala-Fregene v. R. – TCC: Application to file N/O made more than 1 year after expiry of normal period dismissed.


Odebala-Fregene v. The Queen (February 20, 2015 – 2015 TCC 44, Lyons J.).

Précis: On September 2, 2014 the applicant brought an application to extend the time to file Notices of Objection for the 2009 and 2010 taxation years. 849 more words

Income Tax Act

Baribeau v. R. – TCC: CRA cannot open statute-barred year to tax appellant on valueless shares.


Baribeau v. The Queen (February 28, 2011 – 2011 TCC 125).

Précis: Mr. Baribeau worked as an agent for a company (9098) on the sale of a mining property to another company (Mirabel) in 2003 for $140,000. 435 more words

Tax Litigation

George Weston Limited v. R. – TCC: $316,932,896 profit on swap contracts a capital gain – not business income.


George Weston Limited v. The Queen (February 19, 2015 – 2015 TCC 42).

Précis: During its 2003 taxation year George Weston Limited closed swap contracts and realized a profit of $316,932,896. 2,564 more words

Tax Litigation

McBride v. R. – TCC: Monthly payments under divorce taxable even though Superior Court declared them non-taxable.


McBride v. The Queen (February 16, 2015 – 2015 TCC 31).

Précis: Ms. McBride received $13,964 in monthly payments from her ex-husband in 2012. The payments were made pursuant to an Order of the Ontario Superior Court requiring the ex-husband to “pay non-variable and non-taxable spousal support to the Applicant in the amount of $1,163.70” on a monthly basis for 48 months. 1,525 more words

Tax Litigation

Repsol Canada Ltd. v. R. – TCC: Canaport Terminal and Jetty in Saint John, N.B., used for processing, not distribution.


Repsol Canada Ltd. v. The Queen (January 27, 2015 – 2015 TCC 21).

Précis: The Canaport Partnership, of which the appellant was a partner, constructed a terminal and jetty in Saint John, New Brunswick, at which natural gas was unloaded and subsequently entered a pipeline for transmission to consumers. 881 more words

Tax Litigation