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He accepted (at para. 26) the “frustrating event” doctrine from Sazio (2018 TCC 258), but stated (at para. 26): To invoke frustration, the surrounding circumstances must make the frustrating event unforeseeable, beyond the buyer’s control, and deny the buyer any alternative pathway to having the property be their primary residence …. ...

Regarding the Reg. 2401(2)(d) designation, the text and legislative history supported the view that the insurer had the discretion to designate Excess CIF in respect of any of its insurance businesses – even an insurance business (here, the A&S business) that was exempted from tax. ...

(para. 48) “[T]he transactions were structured in the way they were to benefit Corco … [which] needed a way to finance the purchase.” ...

They accomplished what section 160 sought to prevent – its application, they defeated its underlying rationale, and they circumvented its application. ...

Before allowing the taxpayers appeal, Yuan J, stated (at para. 41): I have difficulty imagining what better evidence the CRA could reasonably expect an applicant to produce as proof of filing where the application was submitted by regular mail …. ...

The test is whether … may one say that the building was renovated sufficiently enough that all or substantially all of the building has been removed or replaced: Camiré v. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...

. … I would not expect section 141.01 to deny the input tax credits otherwise determined under subsection 169(1) in the situation where a person is only engaged in commercial activities. ...

Owen J stated (at para. 48) that "this argument fails to recognize that the Advisers are independent contractors and that their use of the subleased space is in furtherance of their own business objectives," noted (at para. 49) "that the Advisers cannot use the subleased space without also using the common-use space," and (at para. 50) that "the direct purpose of the available space was to rent the space to Advisers", which was relevant rather than "the indirect (or ultimate) purpose of having space available … to facilitate the sale of Financial Products. ...

After finding (at para. 40) that “the 2016 amendments … overrode the requirement from prior case law that the tax under the alternative argument had to be derived from the same transaction that produced the originally assessed tax”, he noted that here the alternative bases for denying the interest expense were based on the same transaction being “the borrowing that established the Appellant's obligation to pay the interest expense in the first place” (para. 41). ...