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. … Consistent with the theory of economic allegiance described by the majority in Alta Energy, which recognizes that a recipient of passive income need not have any allegiance to the paying country, the focus of the rationale of Article 10(2) is not how the common shares of Husky came to be owned by the Luxcos, but whether the Luxcos satisfy the residence requirement, the beneficial owner requirement and the voting power requirement. ...

(a)(iii)(B) includes a single individual, so it did not matter that there was only one tenant during the relevant period (para. 11); in the situation, for example, where "two individuals occupy the unit – one for a year and the other for six months –...on the basis that the plural includes the singular, the unit will qualify...by applying the test to the one individual who does occupy the unit for the whole year" (para. 12) "if there is only one occupant of a unit, in order for the unit to qualify based on the actual use test, the unit will have to be occupied by the same individual for a full period of one year (or the shorter period of time contemplated by this clause [((B)])" (para. 20) the phrase "place of residence of individuals" in s. ...

(The taxpayer testified that he spent $104,719 to install a gravel road for ¾ of the property length in order to free up a pick-up truck that had become stuck in peat.) ...

Hershfield J referred (at para. 91) to this being from the perspective of Mall Co a " quid pro quo from ICBC to forego its entitlement against Tech BC. ...

. … CIBC’s answer to question 5591 merely states that…legal advice informed its position. ...

. … [T]he fact that Chapter 2 was introduced partly for the purpose of forestalling tax avoidance schemes self-evidently makes it difficult to attribute to Parliament an intention that it should apply to schemes which were carefully crafted to fall within its scope, purely for the purpose of tax avoidance. ...

Ss. 26(1) and (2) provided that the amount of allowable input tax is that which is “attributable to” taxable “supplies … made or to be made by the taxable person in the course or furtherance of his business.” ...

Wagner and Gason JJ. stated (at paras 17, 19 & 20): Solicitor-client privilege has evolved from being treated as a mere evidentiary rule to being considered a rule of substance and, now, a principle of fundamental justice… …[F]acts connected with that relationship (such as the bills of account at issue in Maranda [2003 SCC 67, [2003] 3 S.C.R. 193 at paras. 33-34]) must be presumed to be privileged absent evidence to the contrary…. ...

. … Hélie Holdco served only to participate in the transaction for the benefit of Mr. ...

Similarly, respecting the divestiture-related fees of Lazard Frères incurred up to board approval of a butterfly spin-off, these related to advice and approaches to potential third-party purchasers of the shares through which the laminated products business was held as well as to the ultimate sale (on a rollover basis) of the shares of that laminated products company to Novelis in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis, and the calculation of the Lazard Frères success fee did not represent a percentage of the value of those shares – so that those fees also were deductible under s. 20(1)(bb) as well as under s. 9. ...