Aquilini (Estate) v. The Queen, 2019 TCC 132
| Court | Tax Court (Canada) |
| Case Date | June 12, 2019 |
| Jurisdiction | Canada (Federal) |
| Citations | 2019 TCC 132 |
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3 practice notes
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Roberto Aquilini et al. v. Her Majesty the Queen,
...Minister that the allocation of net income to the four family trusts was not a reasonable allocation under subsection 103(1.1) of the Act (2019 TCC 132). The Tax Court Judge also addressed the allocation of the losses of another partnership (the GERI partnership) to only Francesco Aquilini,......
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Is Your Partnership Allocation Method Reasonable? The Ability Of Tax Authorities To Reallocate Income And Losses Of A Partnership
...Subsection 96(1) of the Income Tax Act (the ''ITA''). 2 Penn West Petroleum Ltd. v. Canada, 2007 TCC 190 , par. 45 and Aquilini v. Canada, 2019 TCC 132, par. 138-140 (aff'g, 2021 FCA 3 Subsection 103(1.1) of the ITA. 4 Aquilini v. Canada, 2021 FCA 206, par. 34. 5 Id., par. 34 and Aquilini v......
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CaseNotes For December, 2019
...court had no choice but to apply the law to the facts as they were, not as the Appellant intended them. Aquilini (Estate) v. The Queen, 2019 TCC 132- by Sarah Elisa Aquilini and her three sons, Francesco, Roberto and Paolo (the "Taxpayers"), underwent a reorganization of the family assets i......
2 cases
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Roberto Aquilini et al. v. Her Majesty the Queen,
...Minister that the allocation of net income to the four family trusts was not a reasonable allocation under subsection 103(1.1) of the Act (2019 TCC 132). The Tax Court Judge also addressed the allocation of the losses of another partnership (the GERI partnership) to only Francesco Aquilini,......
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Bykov v. The King, 2024 TCC 36
...Will-Kare Paving & Contracting Ltd. v. R., [1996] 2 C.T.C. 2426, at 2434, affirmed 2000 SCC 36, Estate of Elisa Aquilini v. R., 2019 TCC 132, at paragraphs 135 and 136, and 0742443 B.C. Ltd. v. R., 2014 TCC 301, at paragraphs 22 to 26. [14] See paragraph [15] This po......
2 firm's commentaries
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Is Your Partnership Allocation Method Reasonable? The Ability Of Tax Authorities To Reallocate Income And Losses Of A Partnership
...Subsection 96(1) of the Income Tax Act (the ''ITA''). 2 Penn West Petroleum Ltd. v. Canada, 2007 TCC 190 , par. 45 and Aquilini v. Canada, 2019 TCC 132, par. 138-140 (aff'g, 2021 FCA 3 Subsection 103(1.1) of the ITA. 4 Aquilini v. Canada, 2021 FCA 206, par. 34. 5 Id., par. 34 and Aquilini v......
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CaseNotes For December, 2019
...court had no choice but to apply the law to the facts as they were, not as the Appellant intended them. Aquilini (Estate) v. The Queen, 2019 TCC 132- by Sarah Elisa Aquilini and her three sons, Francesco, Roberto and Paolo (the "Taxpayers"), underwent a reorganization of the family assets i......