Words and Phrases - "financial report"
Canada v. Rio Tinto Alcan Inc., 2018 FCA 124
The taxpayer, a Canadian public company listed on the TSX and NYSE and in London, made a hostile bid for a French public company (“Pechiney”). In confirming the finding of Hogan J that expenses of $2.5 million incurred in preparing and sending the takeover bid circular to the Pechiney shareholders were not deductible under s. 20(1)(g)(iii), Pelletier JA stated (at paras. 115-116):
The argument with respect to subparagraph 20(1)(g)(iii) is, in essence, a debate about whether the documents in issue were “financial reports”. …
In this case, the Tax Court found that the relevant documents contained much more than financial information, as was the case in Boulangerie St-Augustin… . The Tax Court found that… it could not determine whether the fees in issue were incurred specifically for the purpose of printing financial information —as opposed to the terms and conditions and other information contained in the documents—and issuing it to Alcan or Pechiney shareholders.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management | dealer and professional fees incurred by a public board in determining to make a bid, as contrasted to implementation, were currently deductible | 348 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company | 492 |