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. … The Agricultural Activities are not carried on independently of the Manufacturing and Processing Activities given Lunick Farm's strategy of vertical integration. ...

In dismissing their appeal, Bouchard JCA indicated that the fact that this was an isolated transaction and that they were not “flippers” was not decisive, the judge had not erred in noting the complete absence of any business plan or other documentary proof of their lack of motivating intention to sell (although, he noted, at para. 34, TaxInterpretations translation, and before referring to Hickman Motors in this regard) that “it is true that there are exceptional situations where the taxpayer manages to demolish the ARQ's assumptions of fact despite the taxpayer’s evidence being limited to the taxpayer’s testimony”) and (at para. 44) that “the judge did not commit a reviewable error … by holding that the appellants had a secondary intention to divest themselves of their project in the event of an interesting offer being made to them.” ...

. … While section 54 ensures that stock option benefits are subject to sections 49 et seq. of the T.A. and excludes them from the scope of sections 36 and 37 [equivalent to ITA ss. 5, 6], it is not, in the absence of clear legislative indications to that effect, a code so complete and airtight that the application of section 422 is excluded. ...

Before confirming the ARQ view (and reversing the decision below), the Court noted that the daughter was not subject to Quebec income tax, referred to the Oceanspan decision as being “particularly illuminating” (para. 44, TaxInterpretations translation), and further stated (at para. 45): The Oceanspan decision was recently cited … in the Marino decision. ...

(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%) …. ...

. … The ARQ correctly argues that it is undisputed in several respects that the award in question was intended to compensate the plaintiffs for an injury directly resulting from the loss of their employment. ...

In the case of a lease, there can be no assignment of the lease to the limited partnership – it must be assigned to the general partner. ...

. … It is therefore necessary to consider, on a document-by-document basis, whether each Sample Document is subject to legal professional privilege. ...

Agence du revenu du Québec, 2022 QCCQ 1175-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Contract Payment- Paragraph (a) expenditures under an agreement to develop software for a 3rd party pursuant to its specifications were not associated with contract payments The taxpayer (“CS Canada”), which carried on a business of developing software for use in the aeronautics industry, entered into a “long term purchase agreement” with a third party (“Pratt & Whitney” or “P&W”) for the sale to it of control system software. ...

The Court found that the application judge- who had noted the contrast between the above representation, and other representations and warranties in the SPA which were limited to the knowledge of the sellers – had reasonably concluded that such representation could be untrue as of the time of closing even if the prospect of reassessment was not reasonably expected by FQM. ...