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Booth of Paradigm Capital, an expert in the valuation of reserves and resource estimates for the oil and gas industry, who concluded that the consideration contemplated by the arrangement was inadequate. ... In reversing the chambers judge and dismissing the application under s. 195, Newbury JA stated (at para 40): … Instead of ‘delving into’ the question of value (see [BCE Inc. v. 1976 Debentureholders, 2008 SCC 69] at para. 141), [the chambers judge] relied on the truism that the shareholders were “entitled to make the decision”. ... Given the ‘red flags’ in this case – the absence of a fairness opinion from an independent expert, the failure of Morgan Stanley to assess the value of the CRP as compared with the value of the PRL prospects (again, the company’s primary asset); the deficiencies pointed out by Mr. ...

ARQ assessed on the basis that Wesdome’s related expenditure did not qualify as Canadian exploration expense under s. 395(c) of the Taxation Act (essentially identical to ITA, s. 66.1(6) – Canadian exploration expense – (f)(vi)), as being “any expense that may reasonably be related to a mine in the mineral resource that has come into production in reasonable commercial quantities or to an actual or potential extension of such a mine.” In confirming the finding of Godbout J below that Wesdome’s expenditures qualified as CEE, Levesque JCA first stated (at paras. 80-81, TaxInterpretations translation): [T]he judge … correctly concluded that the provisions of section T.A. paragraph 395(c) did not require that the exploration expenses were to be incurred respecting a “new mine” to be eligible for tax credits. … [I]f the legislator had wished the contrary, this could have been expressly provided in the provision. ... It is true that the judge assimilated this concept to the fact that the Kiena mine was “in practice … considered as closed.” ...

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. ...

., [2018] HCA 59-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other discounted cash flow valuation undervalued resource lands and residual valuation overstated goodwill Whether the acquisition by Barrick Gold of Placer Dome (“Placer”) triggered Western Australia stamp duty of A$55 million on the lands of in Western Australia of an Australian subsidiary of Placer Dome turned on whether, on a global consolidated basis, the value of all of Placer Dome's land (defined to include mining tenements and improvements) equalled or exceeded 60% of the value of all its property. ... Murry did not broaden the legal concept of goodwill to include sources which did not generate or add value (or earnings) to the business by attracting custom. … … [A]t the acquisition date, there were no sources of goodwill that could explain the $6 billion gap which was attributed by Barrick to goodwill. That unexplained gap suggests that the DCF calculations used by Barrick's valuers to value Placer's land, its principal asset, were wrong. … [T]he danger identified by the majority in Murry of attributing a value to goodwill which actually inheres in an asset was readily apparent. … At the acquisition date, Placer was a land rich company which had no material property comprising legal goodwill. … [italics in original] ...

He stated (at paras. 76-77): The purpose of the Act … is to reduce GHG [green-house gas] emissions on a nation-wide basis. ... Its effect is to put a price on carbon pollution, thereby limiting access to a scarce resource: the atmosphere’s capacity to absorb GHGs. ... Establishing minimum national standards to reduce GHG emissions meets these requirements. … Confining Canada’s jurisdiction to the establishment of minimum national standards to reduce GHG emissions does not result in a massive transfer of broad swaths of provincial jurisdiction to Canada, as Ontario claims. ...

AG Canada, 2018 ONSC 4147-- summary under Charter (Constitution Act, 1982) Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982) unjustified restriction in s. 149(6.2) on public policy advocacy in support of charitable object A registered charity devoted most of its resources to public policy advocacy with a view to ending poverty. ... In response to the Attorney General’s argument that “the Applicant has a right to free speech, not to subsidized speech” through the ability to issue charitable receipts, Morgan J stated (at para. 43): [T]he evidence is that the Applicant cannot function – or will have difficulty in functioning – in the absence of registered charitable status. ...

By the 2009 MOC, students enrolled on the validated courses were to be "considered members of [MU]" but were not entitled to receive university student ID cards and access to university facilities and resources was very limited. Before going on to find that SEL did not qualify as a “college…of…a university” for UK VAT purposes, Patten LJ stated (at paras 64-65): The word "college" … denotes a group of people organised as an institution usually (but not necessarily) in the field of education. ...

Under Reg. 130R12(c) and (e) (the Quebec equivalent of ITA Regs. 1104(9)(c) and (e)), “manufacturing or processing” was deemed to exclude “construction” and “extracting minerals from a mineral resource.” ... (c) exclusion also did not apply, Bourgeois JCQ stated (at para. 44, TaxInterpretations translation): The acquired goods were used exclusively for the handling of materials already collected by the cable excavator, in the context of operations necessary for washing, sorting and crushing and then stacking the various products intended either to be sold to third parties (as to 73.3%) or to be used by the plaintiff (as to 26.67%) …. ...

Boeckh was a closely-held investment company whose portfolio (of over $100 million for many of the years) was focused on junior Canadian public companies in the resource and high tech sectors. ... An interpretation of TA section 250.3 that differed from that of its federal equivalent in ITA subsection 39(5) would derogate from this legislative objective. … [I]n tax matters, where the federal and provincial provisions are appreciably in the same form, a presumption of coherence between the two provisions should prevail. ...

Treaty to impose tax on the royalty payments received by RBC and, in particular, whether they fell within the portion of the definition of “immovable property” in Art. 6(2) (the “fifth limb”) that referred to "rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources". ... In concluding on this issue, she stated (at para. 97): … RBC does not hold, and indeed has never held, an interest in the Buchan field. ...