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Moreover, s. 164(3), which provided for the payment of interest on amounts that are refunded, repaid or applied to another liability of a taxpayer, applied to the Overpayment in relation to the 1995 taxation year – and the taxpayer’s argument implied that for this purpose as well, the day of payment was on June 10, 1995 rather than in February 2000. ...

. … [A] factor that does not include a legally enforceable right and ability to effect a change to the board of directors or its powers, or to exercise influence over the shareholder or shareholders who have that right and ability, ought not to be considered as having the potential to establish de facto control. ...

. … Also paragraph 191.1(2)(c) of the ETA is a condition that, if satisfied, will result in certain consequences under the ETA. ...

. … Accordingly, Callidus was liable to the Crown under s. 222(3) for its pre-bankruptcy breach of the s. 222(1) deemed trust. ...

She concluded (at paras 50 and 51) that as “Menova did not put funds at the disposal of North Shore when it issued the credit memos … section 232 does not apply to the transactions at issue as HST was not credited to North Shore.” ...

. … [T]he CRA’s power to issue requirements under section 231.2 of the ITA to obtain information or documents that will be used for the administrative purpose of reassessing a taxpayer is not suspended by the commencement of an investigation. ...

Canada, 2018 FCA 110-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) s. 152(4.2) inapplicable where reassessment, albeit in response to refund request, increased taxpayer’s liability The taxpayer retired as a partner from Deloitte & Touche LLP in 2007. ...

. … The situation is one in which the mistake should be corrected by a reassessment rather than by finding the assessment to be void. ...

. … [I]t is because interest is, by its nature, symmetrical that the Judge was correct in interpreting subsection 16(1) in the way that he did. ...

In finding that the Tax Court had not committed a palpable and overriding error in this regard Webb JA stated (at para. 43): If the transactions are viewed as only the permits being transferred from Kinderock to the limited partnership and then by the limited partnership to Devonian, … the permits would not be used in an active business being carried on by the limited partnership as they would be transferred immediately upon being received by the limited partnership. ...