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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35 practice notes
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Paletta Estate v. The Queen, 2021 TCC 11
...[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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Grenon v. The Queen, 2021 TCC 30
...of deceit, which is the heart and core of a sham” (p. 573). [363] The Appellant also relies on Cameco Corporation v The Queen, 2018 TCC 195 (“Cameco”) (confirmed on appeal to the Federal Court of Appeal in Canada v. Cameco Corporation, 2020 FCA 112 ) where Owen J. foun......
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Van Der Steen v. The Queen, 2019 TCC 23
...Limited v The Queen, [1997] 2 SCR 336 at 378, ¶92 (SCC); House v The Queen, 2011 FCA 234 , ¶30; and Cameco Corporation v The Queen, 2018 TCC 195, ¶600. [53] Robins v National Trust Company, Limited et al., [1927] A.C. 515 , [1927] 2 DLR 97 , [1927] 1 WWR 692 , ¶8 (PC). See also Cameco......
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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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31 cases
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Paletta Estate v. The Queen, 2021 TCC 11
...[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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Grenon v. The Queen, 2021 TCC 30
...of deceit, which is the heart and core of a sham” (p. 573). [363] The Appellant also relies on Cameco Corporation v The Queen, 2018 TCC 195 (“Cameco”) (confirmed on appeal to the Federal Court of Appeal in Canada v. Cameco Corporation, 2020 FCA 112 ) where Owen J. foun......
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Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67
...in the Tax Court on transfer pricing for prior taxation years was mammoth in size and resulted in a 282 page decision of the Tax Court (2018 TCC 195). The Minister was hardly starting from scratch in this audit, which suggests that requiring interviews of 25 employees may well be overreachi......
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Van Der Steen v. The Queen, 2019 TCC 23
...Limited v The Queen, [1997] 2 SCR 336 at 378, ¶92 (SCC); House v The Queen, 2011 FCA 234 , ¶30; and Cameco Corporation v The Queen, 2018 TCC 195, ¶600. [53] Robins v National Trust Company, Limited et al., [1927] A.C. 515 , [1927] 2 DLR 97 , [1927] 1 WWR 692 , ¶8 (PC). See also Cameco......
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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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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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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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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......