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Section 259 … simply does not lay out any criteria for the exercise of the Minister’s power to designate an entity as a municipality. ...

The submission of Zeifmans- that judicial authorization should have been obtained pursuant to s. 231.2(3) given that the requirement extended to the Unnamed Persons – was rejected essentially because there was “no evidence in the record that the Unnamed Persons [we]re a current investigation target.” ...

Her Majesty the Queen, [1991] 1 CTC 204-- summary under Inserting Words Summary Under Tax Topics- Statutory Interpretation- Inserting Words legislative text can be rectified “to achieve the clear … legislative intent in the face of obstacles created by very minor and patently obvious imperfections of language” In determining that it was inappropriate to effectively rectify an anomaly in the wording of ETA s. 27(1), which made it impossible to calculate the federal sales tax imposed on imported diesel fuel, unless it were interpreted as containing the words "or on the volume," which had been added by a subsequent amendment, McNair J. stated (at p. 212):... ...

Finally, although both the parties might "... have agreed that Ticketnet was liable to pay $2 million to Air Canada for services rendered, a liability that terminated on the good faith non-acceptance of the software... this is not what the contract provide[d]". ...

. … Advisory CIP significantly expands the quantity of relevant evidence that is denied to the courts. ...

In any constitutional climate, the administration of justice thrives on exposure to light — and withers under a cloud of secrecy. 2. ...

In finding that the Report was not protected by solicitor-client privilege, Southcott J stated (at paras 54-55): … I find that its dominant purpose when commissioned and generated was to inform the decision whether to proceed with the transaction and at what price. ...

… [N]either the CRA nor this Court can impose the format in which this information must be provided to the CRA, as all the necessary information has already been provided. ...

Favel J stated (at paras. 50-51): While the record did not contain information stating that the Applicant explicitly requested an extension of time or that he provided the Minister with reasons for requesting an extension of time, Notices of Objection filed after the 90 day delay for objecting, but within the extension of time delay, have been interpreted as implicit applications to extend time …. ...

After having noted that the word “document” (used in s. 288(1)) was defined in s. 123(1) to include “a record” which, in turn, was defined to include “any other thing containing information, whether in writing or in any other form ” (her emphasis), she also rejected (at para. 22) the contention of Tellza that “the request for records in an electronically readable format, along with the system administrator’s user ID and password, where applicable, falls outside the scope of the inspection power in the ETA s 288(1).” ...