Cameco Corporation v. The Queen
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2018 TCC 195 |
| Date | 26 September 2018 |
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48 practice notes
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Canada (National Revenue) v. Cameco Corporation
...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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R. v. Kennedy
...witness capable of making an admission against interest, or was the witness self-serving? [68] Finally, Cameco Corporation v. The Queen, 2018 TCC 195, is frequently cited by the Nova Scotia Supreme Court for the law on distinguishing reliability and credibility at paragraph 11: The reliabil......
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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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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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42 cases
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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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R. v. Kennedy
...witness capable of making an admission against interest, or was the witness self-serving? [68] Finally, Cameco Corporation v. The Queen, 2018 TCC 195, is frequently cited by the Nova Scotia Supreme Court for the law on distinguishing reliability and credibility at paragraph 11: The reliabil......
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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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Burraq Employment Services Ltd. v. The King
...the real one. [151] Justice Owen, as he then was, made a comprehensive review of the concept of sham in Cameco Corporation v. The Queen, 2018 TCC 195 (“Cameco”) (affirmed in Canada v. Cameco Corporation, 2020 FCA 112 ), which I relied upon in these [582] The origin of the modern concept of......
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6 firm's commentaries
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Budget 2025 And The End Of Form-over-substance: Canada's New Transfer Pricing Era
...principle in Article 9 of the OECD Model Convention. Courts were left to fill the gap. In cases such as Cameco Corporation v The Queen (2018 TCC 195, affirmed, 2020 FCA 112), the Tax Court and the Federal Court of Appeal focused heavily on the legal form of intra-group arrangements and on w......
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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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