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The Queen, 2018 TCC 188, aff'd 2020 FCA 4-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) settlement agreement was grounded in reality The Justice Department entered into a settlement agreement with the taxpayer in which it agreed to permit the taxpayer to carryforward an agreed portion of a $23.4M non-capital loss – and then promptly sought to repudiate the agreement on the basis that CRA had discovered that the non-capital loss in question did not exist, so that implementing the settlement would be contrary to law (and, thus, contrary to Galway and CIBC). ...

Agence du revenu du Québec, 2018 QCCQ 9487-- summary under Subsection 296(1) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(1) QBCA did not provide that audit or other proceedings could be commenced against a dissolved corporation The ARQ commenced a QST audit of a corporation (Motostar) after its voluntary dissolution by its sole individual shareholder (Delia) and assessed Motostar for some unremitted QST – and then assessed Delia for the same amount under the Quebec equivalent of ETA s. 323(1) (and ITA s. 227.1(1).) ...

On this basis, the SUV was not an “automobile,” whose ITA definition (applicable also for ETA purposes), excluded a “van or pick-up truck, or a similar vehicle” (interpreted by CRA to include an SUV) “the use of which … is all or substantially all for the transportation of goods, equipment or passengers in the course of gaining or producing income.” ...

Those decisions stand for the proposition that this Court has no jurisdiction to extend the time limit set out in subsection 256.2(7) and thus, no power to order the Minister to allow the Appellant’s Rental Rebate …. ...

I am of the view that an exact register of the hours worked must be provided in order to make an SR&ED claim (Hypercube …). ...

When two or more words that are capable of analogous meaning are coupled together they take their colour from each other, the more general being restricted to a sense analogous to the less general …. ...

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. … I do not require specific details to appreciate what a difficult time this would have been for Ms. ...

Accepting that the word “appeal” refers to the same type of procedure in all these contexts also accords with the presumption of consistent expression, according to which the legislature is presumed to use language such that the same words have the same meaning both within a statute and across statutes …. ...

Canada, 2020 FCA 27-- summary under Subsection 171(2) Summary Under Tax Topics- Income Tax Act- Section 171- Subsection 171(2) an appeal can be bifurcated under s. 171(2) In reversing a decision of the Tax Court judge that s. 171(2) could not be applied to the appeal of the two taxpayers, Nadon J.A. stated (at paras. 2-3): [T]he provision clearly allowed the judge, if he was so inclined in the exercise of his discretion, to give effect to the parties’ request to bifurcate the issues, as per their letter to the Tax Court …. ...