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., insufficient evidence that a proposed enquiry was primarily directed at incriminating the taxpayer) to justify lifting a stay order that had been previously granted, McKeown J. stated, in obiter dicta (at p. 5523): "... it does not appear to me that simply because a court has validated a statute on the basis that it is primarily a regulatory statute, the Department is entitled to bypass any regulatory aspect of it and concentrate solely on bringing penal actions without the need to have any economic input. ...

Shirzad J found that even if the taxpayer’s ETA interpretation were correct, this would not have justified late source-deduction remittances – and that, in any, event “subsections 152(1)(a) and 168(1) of the ETA clearly indicate that the Applicant’s GST/HST payments are due on the date in which the Applicant issues its invoices” (par. 54). ...

He is deemed to have received the Notices of Assessment and Refund Cheques pursuant to subsection 248(7) …. ...

Pinard J found that, given that the advance to the corporation was still outstanding, the interest on a pro rata portion ($65,625/$151,700) of the new loan was deductible, quoting with approval the statement in Shore that “there was in essence the replacement of one borrowing of money for the purposes of [earning income] by another borrowing of money for the same purpose, thus bringing it within subsection 20(3) ….” ...

Collier J stated (at pp. 6112-6113) that although “the plaintiff’s only motivating intention in January 1973 was the acquisition of an investment,” he was “satisfied the plaintiff intended to pursue the strata title scheme from the time she made application to the city” and that “at that stage … the plaintiff intended to convert to inventory.” ...

" In other words, the document was prepared " for the purpose of providing... legal advice" (para. 42). ...

In finding that the lands in question including the 60 acres constituted a former business property "immediately before" their disposition, notwithstanding that after being stripped of the top soil the 60 acres could be no longer utilized as farm land, Rothstein J. stated (p. 6602): "... ...

Accordingly, the requirement that the company have been a Canadian-controlled private corporation " throughout the year" was not met. ...

Cattanach J. then stated (at p. 5389): "... It is important to bear in mind that limited companies that carry on businesses are separate taxable persons.... ...

See summary under Treaties – Art. 27. ...