Canada Revenue Agency Appeals Tax Court of Canada Decision
26 Octubre 2018 - 6:55AM
Cameco (TSX: CCO; NYSE: CCJ) received notification
that the Canada Revenue Agency (CRA) has filed an appeal with the
Federal Court of Appeal regarding the Tax Court of Canada (Tax
Court) decision of September 26, 2018 which found in favour of
Cameco for tax years 2003, 2005 and 2006.
“We are disappointed that the CRA has taken this action after
such a clear and decisive ruling from the Tax Court,” said Tim
Gitzel, Cameco’s president and CEO. “We will continue through the
appeal process and expect the appeal to be decided in our favour as
well.
“We are pleased that the CRA did not appeal Justice Owen’s
decision that sham does not apply,” Gitzel said. “We do not agree
with their remaining grounds for appeal. We hope to have a reasoned
discussion with the CRA to see if we can reach a resolution for all
years based on the principles laid out in the ruling.”
Cameco estimates it would take about two years for the Federal
Court of Appeal to hear and decide the matter.
Decisions of the Federal Court of Appeal may be appealed to the
Supreme Court of Canada, but only if the Supreme Court agrees to
hear the appeal. If an appeal to the Supreme Court is pursued,
Cameco estimates that a further two years would be required to
receive a decision.
Despite CRA’s appeal, Cameco will be making an application to
the court to recover substantial costs incurred over the course of
this case. The actual cost award will be at the discretion of the
Tax Court.
The Tax Court decision and CRA appeal apply only to the 2003,
2005 and 2006 tax years, which were the subject of the original
court case. We expect any further actions regarding subsequent tax
years that have been reassessed (2007 through 2012) will be
suspended until the first three years are finally resolved. The tax
years 2013 and beyond have not yet been reassessed, and it is
uncertain what audit approach the CRA will take. This development
will be discussed further in our upcoming quarterly report and
conference call on November 2, 2018.
Profile
Cameco is one of the world’s largest uranium producers, a
significant supplier of conversion services and one of two Candu
fuel manufacturers in Canada. Our competitive position is based on
our controlling ownership of the world’s largest high-grade
reserves and low-cost operations. Our uranium products are used to
generate clean electricity in nuclear power plants around the
world. Our shares trade on the Toronto and New York stock
exchanges. Our head office is in Saskatoon, Saskatchewan.
Caution Regarding Forward-Looking Information and
Statements
This news release includes statements and information about our
expectations for the future, which we refer to as forward-looking
information. Forward-looking information is based on our current
views, which can change significantly, and actual results and
events may be significantly different from what we currently
expect. Examples of forward-looking information in this news
release include our intention to continue through the appeal
process, our expectation the appeal will be decided in our favour,
the timing for various steps in the appeals process and our
expectation that any further actions with CRA regarding other tax
years will be suspended until the first three years are finally
resolved. Material risks that could lead to different results
include unexpected developments in the appeals process, timing
delays, or CRA taking a different approach to subsequent tax years
than we expect. In presenting this forward-looking
information, we have made assumptions which may prove incorrect
about the appeals process and its timing, and CRA’s approach to
subsequent tax years. Please see our most recent management’s
discussion and analysis for discussion of additional risks and
assumptions. Forward-looking information is designed to help you
understand management’s current views of our near-term and
longer-term prospects, and it may not be appropriate for other
purposes. We will not necessarily update this information unless we
are required to by securities laws.
Investor inquiries: Rachelle
Girard
306-956-6403
Media
inquiries:
Carey Hyndman
306-956-6317
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