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The Tax Court dismissed Brad Milne’s CERS appeal, holding that a studio in his rented home was part of a self-contained domestic establishment and not a qualifying property.
La Cour accueille la requête du ministre et rejette l’appel après le défaut de l’appelant de comparaître à un interrogatoire préalable et son recours à des arguments pseudo-juridiques.
Paletta Estate correctly interprets Stewart and Walls; where objective evidence shows an activity that appears commercial was undertaken with the purpose of realizing a loss rather than pursuing profit, that activity is not a source of income; the Tax Court properly applied this principle to find the appellant intended to incur a loss and thus had no source of income, so the reassessment was correctly confirmed.
Source excerpt
The Tax Court quashed a large corporation’s appeals for 2020–2022 because its notices of objection did not satisfy the statutory objection requirements.
The Tax Court granted the Crown’s motion to quash, holding it lacked jurisdiction to order a downward transfer pricing adjustment in computing FAPI.
The Tax Court dismissed William McCutcheon’s appeals and upheld s. 163(2) penalties, finding he was wilfully blind to false business and capital loss claims.
The Tax Court confirmed Part XIII withholding tax and penalties on rental payments to a UK company, finding it was the beneficial owner and not an agent for Norway.
The Tax Court allowed Paul Ratti’s appeal, holding his employment income was qualifying revenue for CEWS purposes and that personal domestic-worker wages did not bar entitlement.
The Tax Court addressed seven related tax appeals involving reassessments, shareholder benefits, shareholder loans, HST adjustments and gross negligence penalties.
La Cour canadienne de l'impôt a ordonné aux procureurs du requérant de payer personnellement 625 $ en dépens pour leur absence à l'audience du 10 juillet 2025.
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