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In this regard, he stated (at para. 47, citing Wild): [I]t is now established that the modification of tax attributes, such as an increase in a taxpayer’s CDA, does not give rise to a tax benefit unless and until a capital dividend is paid out of that account to a recipient capable of benefiting from its tax-free character …. ...

The following question was posed under Rule 58: Where the Minister has at all times concluded that no partnership existed, can the Minister issue a valid Notice of Determination in respect of that purported partnership under subsection 152(1.4) …. ...

In this regard, he noted (at para. 74) the statement in Symes that “Courts will … look for objective manifestations of purpose,” and then stated (at para. 76): [S]ubsequent actions or steps taken by Keybrand or [its parent] BWS could be used to either confirm or contradict Keybrand’s stated purpose in borrowing the funds to acquire the shares of Vidabode. ...

Since the TCC’s enhanced cost order (under Rule 147(7)) was wholly contingent on the order it made in the underlying action, when that order was reversed, its Rule 147(7) order was rendered a nullity – there was nothing for the Crown to appeal. ...

. … The Tax Court Judge was not bound by any admission that CIBC was paying for Aeroplan Miles in light of the agreement, which was properly tendered as evidence at the Tax Court hearing, and which clearly states that the payments made by CIBC were in consideration of Aeroplan “referring or arranging for Aeroplan Members and other members of the public to make Card Applications”. ...

. … The Tax Court Judge was not bound by any admission that CIBC was paying for Aeroplan Miles in light of the agreement, which was properly tendered as evidence at the Tax Court hearing, and which clearly states that the payments made by CIBC were in consideration of Aeroplan “referring or arranging for Aeroplan Members and other members of the public to make Card Applications”. ...

. … Evidence contradicting the taxpayer’s arguments included: Each house was listed for sale before the occupancy permit was obtained. ...

. … However, the self-supply rules do not apply if the conditions as set out in subsection 191(5) of the ETA are satisfied. ...

. … Vavilov recognizes the shortcomings in the former law and fixes them. ...

Canada, 2021 FCA 182-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose essential certainty that a film would be resold under an “option” before it generated any revenue established that s. 18(1)(a) not satisfied Hogan J had found that a tax shelter partnership, which had funded the prints and advertising expenses for films that it had purchased from Twentieth Century Fox, had not incurred such expenses for an income-producing purpose because there was no real prospect that Fox would not exercise its “options” to repurchase the films – and thus no real prospect that the films would generate revenue to the partnership. ...