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. … Accordingly, Callidus was liable to the Crown under s. 222(3) for its pre-bankruptcy breach of the s. 222(1) deemed trust. ...

. … However, the new replaced area of the roof, half the roof, is inseparable from the floor of the garage below it and from the entire garage. ...

. – of which 3.75% of p.a. was required to be paid annually in cash (“cash-pay interest”) and with the balance was capitalized each year (“capitalized interest”). ...

The Court concluded (at para. 16, TaxInterpretations translation): [I]f SARL Google France had the character of dependent agent within the meaning of (c) of paragraph 9 of Article 2 of the French-Irish Tax Convention, it nonetheless did not exercise, in the years under litigation, the power to bind Google Ireland Limited in commercial relations respecting the transactions constituting the activities of the latter corporation; it follows from this that the Service was incorrect in considering that Google Ireland Limited exercised, through a permanent establishment that was formed by SARL Google France, an activity in France within the meaning of section 182 of the General Income Tax Code …. ...

It follows that, assuming that each ‘variation of income’ resolution was authorised by the relevant trust deed, the applicant was not “presently entitled” to a share of the net income of the trust estate … for [that] year…. ...

After rejecting the equivalence of other services of PIC and WSL, he concluded (at para 93): [I]t has not shown that, in the absence of the services provided by WSL and PIC, it would have required more than five full-time employees throughout the years in issue … it carried on a specified investment business in those years. ...

Before dismissing DGGMC’s appeal, she stated (at paras. 51-53, Tax Interpretations translation): Here we are not concerned with … a seizure outside of Quebec which, it is true, could require the seizing party to approach an authority of the foreign State with a view to obtaining its collaboration in order to proceed. ...

Thus, the right to deduct VAT charged on the acquisition of input goods or services presupposes that the expenditure incurred in acquiring them was a component of the cost of the output transactions that gave rise to the right to deduct … [36] In this case, in view of the fact that, first, a share issue is an operation not falling within the scope of the [Directive] and, second, that operation was carried out by Kretztechnik in order to increase its capital for the benefit of its economic activity in general, it must be considered that the costs of the supplies acquired by that company in connection with the operation concerned form part of its overheads and are therefore, as such, component parts of the price of its products. ...

She concluded (at paras 50 and 51) that as “Menova did not put funds at the disposal of North Shore when it issued the credit memos … section 232 does not apply to the transactions at issue as HST was not credited to North Shore.” ...

. … Mr. Demers is an experienced director. Nothing permitted him to believe that the cosmetic changes made to the structure of the Corporation sufficed to change its tax obligations and to terminate its obligations to collect and remit the source deductions for personnel. ...