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The parties returned with a revised plan of arrangement which had essentially the same proposed terms, except that contingent cash consideration to be paid to the InterOil shareholders based on the subsequently-measured size of InterOil’s natural gas resource was capped once the assessed size reach 11 trillion cubic feet equivalent rather than 10 tcfe. ... In addition, Interoil provided the shareholders with considerable information on the value of the new Arrangement and the value of the contingent resources; b) the Transaction Committee was independent, examined and endorsed the arrangement; c) the Fairness Opinion was independent and addressed the deficiencies of the previous fairness opinion; d) the shareholders had access to dissent and appraisal remedies and those who indicated they wished dissent rights were reduced from 10% on the first plan of arrangement to 1 % on the new plan of arrangement. ...

After confirming the decision of the Minister to revoke the registration of the Foundation under s. 168(1)(e) on the grounds of essentially no records substantiating the consulting fees (and in finding that the decision of the Minster to revoke under s. 168(1)(b) on the grounds that the consulting fees had not been established to satisfy the requirement for the Foundation to devote all of its resources either to charitable activities or as gifts to qualified donees, Woods JA stated (at paras. 53, 57): … The Appeals Directorate noted that most of the funds received and disbursed by the Foundation were to registered charities in which …[Mr. ... In this case, the question is not whether the Minister ignored gifts to qualified donees, but whether the Foundation used some of its resources to pay [Mr. ...

Canada (Attorney General), 2022 FC 198-- summary under Subsection 85(7.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(7.1) taxpayer worse off for filing s. 97(2) elections on a timely basis rather than late In January 2015, the taxpayer transferred resource properties to a limited partnership that was wholly-owned by it, directly and indirectly. ... In dismissing the taxpayer’s application for judicial review, Aylen J stated (at paras. 41-42, 53): I am satisfied that the Applicant’s “explanation” was so devoid of particulars that it did not amount to an explanation at all. … The Applicant … failed to explain in any meaningful way why it would be just and equitable for the Minister [grant the request]. … I am not satisfied that the Applicant has demonstrated any error by the Minister’s delegate in his finding that the amendment requests constituted an attempt to circumvent the successor rule stipulated in section 66.7 …. ...

" the taxpayer to whom reference is made in s. 1204(1)(b), rather than referring to "... the oil and gas business, the production of it... ... Accordingly, general and administrative expenses relating not to wells which generated revenues, but to activities intended to result in the acquisition of new wells, did not reduce the resource profits under s. 1204(1). ...

The Queen, 2015 TCC 191 (Informal Procedure)-- summary under Regulation 3100 Summary Under Tax Topics- Income Tax Regulations- Regulation 3100 notes were prescribed benefit where no intention to demand payment Lyons J found (at para. 42) that the taxpayers were not required by Blue Hill, the promoter of a tax shelter investment in mineral claims, to pay the promissory notes issued by them in consideration for Blue Hill incurring Canadian resource expenditures on their behalf. ... See summary under s. 237.1(1) – tax shelter. ...

Burke was entitled to none of the benefits, she stated (at paras. 116-117): This, as well as other factors identified … at paragraph 142 of Vavilov such as concerns about delay, fairness to the parties, costs to the parties and the efficient use of public resources, support a finding that the matter should not be remitted to the Appeal Division for redetermination. … Declining to remit a matter to the administrative decision maker may also be appropriate where it becomes evident to the Court that a particular outcome is inevitable …. ...

Applying the presumption against tautology, Parliament thus intended a corporate party to be able to be represented by either counsel or some third party individual who was not a lawyer. … … [M]eaning must be given to the clear subsection 17.1(1) Parliamentary language that a party, a term encompassing both corporate and non-corporate parties, may appear in person in a general procedure appeal. ... Additionally, …the “outside accountant” potentially … would be an important if not key witness at any hearing of this appeal. … For these two reasons I will dismiss the corporate Appellant’s application per Rule 30(2)…. The Rules do not seem to provide for an application for individuals who are appellants in general procedure appeals to be represented by anyone other than either counsel or themselves. … ...