Colitto v. The Queen, 2019 TCC 88
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2019 TCC 88 |
| Date | 26 April 2019 |
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7 practice notes
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Keep Your Eye On The Time: Timing Liability Under Subsection 160(1) In Eyeball Networks
...the phrases at the time and at that time in subparagraph 160(1)(e)(i), see Hardtke (2015 TCC 135) at paragraph 33 and Colitto (2019 TCC 88) at paragraph 35. Read the original article on The content of this article is intended to provide a general guide to the subject matter. Specialist ......
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The Transfer Of Property To A Spouse: An Operation With No Consequences?
...Act, R.S.Q., c. A-6.002 and section 1034 of the Taxation Act, C.Q.L.R., c. I-3. 3 See subsection 160(2) I.T.A. 4 Colitto v. The Queen, 2019 TCC 88. 5 See paragraph 227.1(2)(a) The content of this article is intended to provide a general guide to the subject matter. Specialist advice should ......
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Double Derivative Tax Liability: How Does Derivate Tax Liability Under Section 160 Interact With Derivative Tax Liability Of A Director Under Section 227.1? Colitto v The Queen (2019 TCC 88) A Canadian Tax Lawyer's Analysis
...the corporation's unremitted source deductions. (The Excise Tax Act contains analogous rules relating to GST/HST.) Colitto v The Queen (2019 TCC 88) considered how these two rules interactin particular, when may one taxpayer's derivative liability under section 227.1 pass to another taxpay......
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Double Derivative Tax Liability: The Federal Court Of Appeal Broadens The Scope Of Derivative Tax Liability For Directors And For Non-Arm's-Length Transferees ' The Queen V Colitto (2020 FCA 70) ' A Canadian Tax Lawyer's Analysis
...EI, and employee income-tax withholdings). The Excise Tax Act contains analogous rules relating to GST/HST debts. In Colitto v The Queen (2019 TCC 88) and The Queen v (2020 FCA 70), the Tax Court of Canada and the Federal Court of Appeal respectively considered-and reached opposing conclusi......
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1 cases
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Canada v. Colitto, 2020 FCA 70
...notices of objection in respect of the assessments and subsequently appealed to the Tax Court of Canada. [9] For reasons cited as 2019 TCC 88, the Tax Court allowed the respondent’s appeals on the ground that Mr. Colitto’s personal liability under section 227.1 of the Ac......
6 firm's commentaries
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Keep Your Eye On The Time: Timing Liability Under Subsection 160(1) In Eyeball Networks
...the phrases at the time and at that time in subparagraph 160(1)(e)(i), see Hardtke (2015 TCC 135) at paragraph 33 and Colitto (2019 TCC 88) at paragraph 35. Read the original article on The content of this article is intended to provide a general guide to the subject matter. Specialist ......
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The Transfer Of Property To A Spouse: An Operation With No Consequences?
...Act, R.S.Q., c. A-6.002 and section 1034 of the Taxation Act, C.Q.L.R., c. I-3. 3 See subsection 160(2) I.T.A. 4 Colitto v. The Queen, 2019 TCC 88. 5 See paragraph 227.1(2)(a) The content of this article is intended to provide a general guide to the subject matter. Specialist advice should ......
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Double Derivative Tax Liability: How Does Derivate Tax Liability Under Section 160 Interact With Derivative Tax Liability Of A Director Under Section 227.1? Colitto v The Queen (2019 TCC 88) A Canadian Tax Lawyer's Analysis
...the corporation's unremitted source deductions. (The Excise Tax Act contains analogous rules relating to GST/HST.) Colitto v The Queen (2019 TCC 88) considered how these two rules interactin particular, when may one taxpayer's derivative liability under section 227.1 pass to another taxpay......
-
Double Derivative Tax Liability: The Federal Court Of Appeal Broadens The Scope Of Derivative Tax Liability For Directors And For Non-Arm's-Length Transferees ' The Queen V Colitto (2020 FCA 70) ' A Canadian Tax Lawyer's Analysis
...EI, and employee income-tax withholdings). The Excise Tax Act contains analogous rules relating to GST/HST debts. In Colitto v The Queen (2019 TCC 88) and The Queen v (2020 FCA 70), the Tax Court of Canada and the Federal Court of Appeal respectively considered-and reached opposing conclusi......
Request a trial to view additional results