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He stated that there indeed was consideration going the other way in the form of “Newco in turn … surrender[ing] the shares which had a corresponding $30 million value in its hands” (para. 69). ...

True, at that point Oldco had divested itself of its most valuable business assets – but it held in lieu thereof Newco preferred shares to be redeemed for a $30M note owing to it by Newco, which had those assets. ...

If it is unambiguous, it will generally be sufficient to apply it, as the purpose of the provision cannot be used to create an implied exception to what is otherwise clearly set out …. ...

The Queen, 2021 TCC 13-- summary under Subsection 49(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 49- Subsection 49(1) “taking note” of a fact pleaded by the taxpayer is not a permitted Crown response Graham J concluded his reasons by stating: Paragraphs 49(1)(a) to (c) … require that a reply to a notice of appeal state the facts in the notice of appeal that are admitted, the facts that are denied and the facts of which the respondent has no knowledge and puts in issue. ...

. … Irrespective of the applicable section of the Copyright Act, it is clear that Appellant was assessing the purchase of rights. ...

. … Accordingly, where an admission is contradicted by the evidence, the admission should be regarded as having been made in error. ...

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

. … I cannot find that the loan was repaid before the end of [the corporation’s] 1988 taxation year. ...

(k.1) In finding that the recurring costs of racks and boxes incurred by an exploration company in order to store core samples were capital expenditures, Fournier J stated (at para. 295, TaxInterpretations translation): The core boxes and racks allowed for the permanent preservation of a duplicate of each sample taken during exploration …. ...

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) ….” ...