Laliberté v. Canada, 2020 FCA 97
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Court of Appeal (Canada) |
| Date | 29 May 2020 |
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7 practice notes
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Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
...was a ‘disposition’ for a party to 65 Youngman , above note 62 at para 19. 66 Fingold , above note 63 at para 13; Laliberté v Canada , 2020 FCA 97. 67 Hewlett Packard (Canada) Ltd v Canada , 2004 FCA 240 [ Hewlett Packard ]. 68 The word “disposition” is deined in the Act as any transactio......
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Jackman v. The Queen, 2022 TCC 73
...is the approach I was required to take in Laliberté v HMQ, 2018 TCC 186, and that approach was upheld by the Federal Court of Appeal, 2020 FCA 97 at paragraph 56. :14.0pt;"> The appeals from the reassessments made under the Income Tax Act for the 2013 and 2014 taxation years are allowe......
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Jefferson v. Canada, 2022 FCA 81
...in the passage from Hickman. [22] The appellant’s argument is similar to that advanced by the taxpayer in Laliberté v. Canada, 2020 FCA 97, 2020 D.T.C. 5052 [Laliberté]. There, the taxpayer was assessed a significant shareholder benefit because a corporation of which he was......
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A Canadian Tax Lawyer's Perspective On An Out Of This World Shareholder Benefit Decision ' Laliberté v. Canada
...of that person becoming a shareholder. The taxation of shareholder's benefits starred in the recent case of Laliberté v. Canada 2020 FCA 97. The Factual Background of Laliberté v. Guy Laliberté is the founder of Cirque du Soleil. In 2009, he completed his long term dream of visiting the Int......
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3 cases
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Jackman v. The Queen, 2022 TCC 73
...is the approach I was required to take in Laliberté v HMQ, 2018 TCC 186, and that approach was upheld by the Federal Court of Appeal, 2020 FCA 97 at paragraph 56. :14.0pt;"> The appeals from the reassessments made under the Income Tax Act for the 2013 and 2014 taxation years are allowe......
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Jefferson v. Canada, 2022 FCA 81
...in the passage from Hickman. [22] The appellant’s argument is similar to that advanced by the taxpayer in Laliberté v. Canada, 2020 FCA 97, 2020 D.T.C. 5052 [Laliberté]. There, the taxpayer was assessed a significant shareholder benefit because a corporation of which he was......
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Boyd B. Harding v. Her Majesty the Queen, 2022 TCC 3
...[12] Pillsbury Holdings Ltd. v MNR (1964), [1965] 1 Ex CR 676 at 682-683 [Pillsbury]. [13] Ibid at 684-685. [14] Laliberté v Canada, 2020 FCA 97. Ibid at paras 33-35. [16] Transcript of the hearing of this appeal at 15 and 172 [Transcript]. [17] Transcript at 58. [18] Notice of Appeal ......
3 firm's commentaries
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A Canadian Tax Lawyer's Perspective On An Out Of This World Shareholder Benefit Decision ' Laliberté v. Canada
...of that person becoming a shareholder. The taxation of shareholder's benefits starred in the recent case of Laliberté v. Canada 2020 FCA 97. The Factual Background of Laliberté v. Guy Laliberté is the founder of Cirque du Soleil. In 2009, he completed his long term dream of visiting the Int......
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Space Travel And Taxes: A Cautionary Tale Of Shareholder Benefits
...recent decision in Laliberté v Canada, 2020 FCA 97, [Laliberté] the Federal Court of Appeal that the $41.8-million costs of a shareholder's visit to outer space as a "space tourist" should be taxed as a shareholder benefit, and not as a deductible marketing expense as was claimed by the sha......
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Space Travel and Taxes: A Cautionary Tale of Shareholder Benefits
...recent decision in Laliberté v Canada, 2020 FCA 97, [Laliberté] the Federal Court of Appeal confirmed that the $41.8-million costs of a shareholder's visit to outer space as a "space tourist" should be taxed as a shareholder benefit, and not as a deductible marketing expense as was claimed ......
1 books & journal articles
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Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
...was a ‘disposition’ for a party to 65 Youngman , above note 62 at para 19. 66 Fingold , above note 63 at para 13; Laliberté v Canada , 2020 FCA 97. 67 Hewlett Packard (Canada) Ltd v Canada , 2004 FCA 240 [ Hewlett Packard ]. 68 The word “disposition” is deined in the Act as any transactio......