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Tax Court Nailed Taxpayer's Insurance Plan: Morrissette Case And What It Means

A recent case, Morrissette, addressed a complex intergenerational split dollar (ISGD) life insurance plan and handed a costly defeat to the taxpayer. ....

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The Tax Court in Brief - May 2021 #2 | Freeman Law

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Taxpayer, a state senator with 30 years of service, was convicted on Federal criminal charges, including mail and wire fraud. One victim included a 501(c)(1) & (3) organization, exempt from Federal income tax. Taxpayer influenced the tax-exempt organization’s formation as, at his direction, three members of his senatorial staff incorporated the organization for the purposes of maintaining and improving the aesthetic appearance of the taxpayer’s district. At all periods in question, at least one member of the taxpayer’s staff worked for the charity organization as either President or Executive Director while remaining employed by the Senator. Taxpayer influenced, as chairman of a senate appropriations committee, funding for the charitable entity from public and private sources. ....

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Tax Court Decision Overturned: Visa Does Supply GST/HST Exempt

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On January 22, 2021, the Federal Court of Appeal (the
“FCA”) overturned the Tax Court of Canada s
dismissal
1 of a Canadian bank s (the
“Bank”) appeal in connection with the Bank s
claim for GST/HST rebates for tax paid in error.
2 While the Tax Court
had originally found that the transaction processing services
provided by Visa Canada (“Visa”) for the credit cards
issued by the Bank constituted a taxable supply, the FCA was of the
view that such supply was an exempt “financial service”
that was not otherwise excluded pursuant to the specific ....

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