Cameco Corporation v. The Queen, 2018 TCC 195
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2018 TCC 195 |
| Date | 26 September 2018 |
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38 practice notes
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Paletta Estate v. The Queen,
...[247] There is no better way to conclude my analysis of sham than to adopt the words of Justice Owen in Cameco Corporation v The Queen, 2018 TCC 195. I find as a fact that Mr. Pat Paletta and the brokerage houses: [670] … did not factually represent the numerous legal arrangements th......
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Magren Holdings Ltd v. Canada,
...neither a tax motivation nor taking steps to implement a “tax plan” by itself constitutes a sham, citing Cameco Corporation v. The Queen, 2018 TCC 195, [2019] 1 C.T.C. 2001 (aff’d 2020 FCA 112, [2020] 4 F.C.R. 104, leave to appeal to SCC refused, 39368 (18 February 2021) at paragraph 605: r......
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Chad v. The King,
...part A, second paragraph. As noted above, Mr. Broer’s revised report was entered as Exhibit A‑93. [104] Cameco Corporation v. The Queen, 2018 TCC 195, ¶592 (Justice Owen’s finding that there was not a sham was not appealed; see 2020 FCA 112 , ¶15). [105] Exhibit A‑4. [106] Exhibit A‑5. [10......
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R. v. Drake,
...Detective Constable MacAdam. The relationship between the two concepts was explained in Cameco Corporation v. The Queen, 2018 TCC 195, affirmed, 2020 FCA 112, leave to appeal refused, [2020] S.C.C.A. No. [11] The reliability of a witness......
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34 cases
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Paletta Estate v. The Queen,
...[247] There is no better way to conclude my analysis of sham than to adopt the words of Justice Owen in Cameco Corporation v The Queen, 2018 TCC 195. I find as a fact that Mr. Pat Paletta and the brokerage houses: [670] … did not factually represent the numerous legal arrangements th......
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Magren Holdings Ltd v. Canada,
...neither a tax motivation nor taking steps to implement a “tax plan” by itself constitutes a sham, citing Cameco Corporation v. The Queen, 2018 TCC 195, [2019] 1 C.T.C. 2001 (aff’d 2020 FCA 112, [2020] 4 F.C.R. 104, leave to appeal to SCC refused, 39368 (18 February 2021) at paragraph 605: r......
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Chad v. The King,
...part A, second paragraph. As noted above, Mr. Broer’s revised report was entered as Exhibit A‑93. [104] Cameco Corporation v. The Queen, 2018 TCC 195, ¶592 (Justice Owen’s finding that there was not a sham was not appealed; see 2020 FCA 112 , ¶15). [105] Exhibit A‑4. [106] Exhibit A‑5. [10......
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R. v. Drake,
...Detective Constable MacAdam. The relationship between the two concepts was explained in Cameco Corporation v. The Queen, 2018 TCC 195, affirmed, 2020 FCA 112, leave to appeal refused, [2020] S.C.C.A. No. [11] The reliability of a witness......
Get Started for Free
4 firm's commentaries
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What's New In Tax Controversy And Litigation?
...Prévost Car Inc. v. Canada, 2009 FCA 57; Velcro Canada Inc. v. The Queen, 2012 TCC 57, respectively. 8 2018 TCC 182. 9 2019 TCC 62. 10 2018 TCC 195. 11 2019 FC The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about ......
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FCA Refuses To Pierce The Corporate Veil In Cameco Transfer Pricing Case
...parties are conducted on arm's lengths terms and conditions. Footnotes 1 The Queen v Cameco Corporation, 2020 FCA 112 [Cameco (FCA)] 2 2018 TCC 195 [Cameco 3 RSC 1985 c. 1 (5th Supp.) [Income Tax Act]. 4 The Crown has 60 days from the date of the FCA decision to seek leave to appeal to the ......
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From Transfer Pricing To Tax Treaties: Canadian Cross-Border Tax Update
...transfer-pricing dispute On September 26, the Tax Court of Canada released its decision in Cameco Corporation v Her Majesty the Queen, 2018 TCC 195. The Minister of National Revenue reassessed Cameco Corporation (Cameco Canada) to include in its taxable income all of the uranium trading pro......
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Ain't That A Shame - That Ain't A Sham
...and diligent execution should not be overwhelmed by unsupported assertions that tax planning is naughty, thus a sham. Footnotes [1] 2018 TCC 195. [2] 2018 TCC 230 [3] [1967] 1 All E.R. 518 ("Snook"). [4] [1984] 1 S.C.R. 536 ("Stubart"). [5] {1987] 1 SCR 32. [6] 2009 TCC 465 ("Antle") (aff'd......