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

By committing itself to issuing 1,380,000 shares to a trust for the benefit of all eligible employees, the Company failed to meet the requirements of subsections 7(1) and 7(2) …. ...

By committing itself to issuing 1,380,000 shares to a trust for the benefit of all eligible employees, the Company failed to meet the requirements of subsections 7(1) and 7(2) …. ...

. … [T]he fair market value of a business as a going concern plays no role in determining the proceeds of disposition, or consequential recapture, of depreciable property under the Act. ...

In finding that s. 160 applied to the transactions in light inter alia of the cash proceeds received by Harvard Properties exceeding the FMV of the Newco shares sold by it, Boyle J found (at para. 166) that Harvard Properties had failed to establish any value for the shares, stating (at para. 174): There appears to be little to no chance that any arm’s length party unrelated to these transactions would agree to accept, much less pay for, the HP Newco shares at the relevant time as the Newcos would moments in time later have no assets, no business, and the possibility of a significant liability for their roles in these transactions …. ...

. – whereas here the taxpayers had substantiated the existence of an RCA by obtaining an actuarial report to support the amount of contributions necessary to provide them with a reasonable pension on retirement. ...

. … Despite his unusual lifestyle and his propensity to ridicule his opponents, the appellant was a serious businessman. ...

. … The same rationale applicable to income tax assessments must logically apply to CEWS determinations, namely, individual notices of determination may be appealed in a single notice of appeal without coalescing. ...

II, s. 1 – home care service. ...

Although the transactions entailed surplus stripping, "it is doubtful whether in an integrated corporate/shareholder tax system, a surplus strip per se can be said to abuse the spirit and object of the Act " (para. 101). ...