- Parties: The appellant was Husky Energy Inc. The respondent was His Majesty the King.

- Subject Matter: This appeal sought to set aside a Tax Court of Canada judgment, which dismissed with costs the appellant's appeal of a notice of assessment dated Jan. 15, 2015 and made under Part XIII of the Income Tax Act, 1985 (ITA). The Part XIII appeal concerned the determination of the applicable withholding tax rate on dividends that the appellant paid to Hutchison Whampoa Europe Investments S.à.r.l. and L.F. Luxembourg S.à.r.l. on Oct. 1, 2003. The appeal alleged that the Tax Court judge erred in law and in fact in his interpretation and application of ss. 212(2), 215(1), and 215(6) of the ITA; s. 10(6) of the Income Tax Application Rules; and article 10(2) of the Convention between the Government of Canada and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, including by determining that the non-resident corporations were not the dividends' beneficial owners. This case is ongoing.

- Date: The hearing was set on Dec. 3, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: No financial award was specified.