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Finally, Smith J found (at para 58): As indicated… in Kyte … there may be discrepancies as the amounts owed for source deductions may be fluid. ...

. … However, the new replaced area of the roof, half the roof, is inseparable from the floor of the garage below it and from the entire garage. ...

. – of which 3.75% of p.a. was required to be paid annually in cash (“cash-pay interest”) and with the balance was capitalized each year (“capitalized interest”). ...

After rejecting the equivalence of other services of PIC and WSL, he concluded (at para 93): [I]t has not shown that, in the absence of the services provided by WSL and PIC, it would have required more than five full-time employees throughout the years in issue … it carried on a specified investment business in those years. ...

. … However, the Appellant argues that it is a resident of the Netherlands where it is domiciled (though no expert evidence was lead on the issue of Dutch law) in which case it is possible to conclude that the Appellant “is a resident of both States”. ...

This provision would have deemed the shares of Alta Canada to be immovable property (thereby permitting the gain from their disposition to be subject to Canadian capital gains tax) on the basis that they derived their value principally from immovable property situated in Canada, subject to an exclusion which deemed the underlying licences not to be immovable property if they were property of Alta Canada “in which the business of the company … was carried on.” ...

Paletta International reported a loss of US$96.1 million from the partnership, which mostly related to its share of the P&A expenses – and also reported a capital gain from the disposition of its partnership units (but took advantage of the 5-year capital gains reserve.) ...

. … The Crown has not persuaded me that in 2008 and 2009 the purpose of the Reduction Provision was to do anything other than to reduce the addition of life insurance proceeds to a corporation’s capital dividend account by the amount of the adjusted cost basis of the life insurance policy to that corporation. ...

Monaghan J stated (at para. 213): … The Tax Court will address all challenges to the correctness of the assessment made after the transfer pricing provisions have been applied, including whether the conditions for their application are met, the amount of any adjustments, the liability for penalties and whether the Minister exercised her discretion properly. ...

. … If the Minister agrees with Mr. Turski, and indeed with me, that the application of the 36-month rule in this case seems to lead to an unfair and unreasonable result, and that the public interest that led to the adoption of that rule does not apply in this case- and I hope the Minister will so agree- then the Minister will ask Cabinet to approve the remission order. ...