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In finding that its resulting foreign exchange gains and losses were realized under s. 95(2)(f) on income account, C Miller J stated (para. 276): The acquisition of the short term securities, taking their yield and funding a derivatives program to produce a greater yield is … using these short term securities in a manner akin to inventory in an income producing scheme. ...

. … [T]he remaining 90% of the cost of the trip, being $37.6 million, was the amount of the benefit conferred on and enjoyed by M. ...

CRA denied her extension request under ETA s. 256(3)(b) (providing for an extension to any “date that the Minister may allow” on the grounds that the Guide disclosure was not inaccurate – and none of the other published grounds for taxpayer relief were met. ...

CRA assessed him advantage tax under s. 207.05 equalling 100% of the appreciation of the shares within his TFSA before the shares’ sale – and following a Federal Court action by him, proposed to reduce the rate of advantage tax to his marginal federal and provincial tax rate. ...

The [definition] … by no means speaks to specifically allowing different financial year-ends for Quebec purposes. ...

In confirming this assessment, Owen J found (at para. 127): … Since the pharmaceuticals were not (and could not be) imported into Canada for sale, the approach to valuation adopted for the CGI Program is patently flawed since it is using a Canadian market (Ontario) to value generic pharmaceuticals that cannot be sold in that market. ...

After noting (at para. 65) that “the information required by subsection 169(4) … may be contained collectively in multiple documents,” Sommerfeldt J noted that whether s. 3(a)(ii) or (iii) of the Input Tax Credit Information (GST/HST) Regulations applied turned on whether DCML had issued an invoice to the appellant. ...

After noting that essentially noting (at para. 45) that “the Tendances et Concepts case may not carry as much weight now, given that it was based on a previous French version of the ETA, in which arrhes was used as the French equivalent for the English deposit ” and that (notwithstanding North Shore Power) IHI’s making of interim payments could have been consistent with their being deposits, Sommerfeldt J stated (at para. 54): [T]he payment structure set out in [the] email of December 7, 2007 has a broad similarity to the payment structure in North Shore Power. ...

. … To ignore the construction component of the Appellant’s business would be an incorrect interpretation of the phrase “derived primarily from”. ...

In finding that Delia would be liable under an assessment made of him for the above amount plus interest under the Quebec equivalent of ITA s. 227.1 (s. 24.0.1 of the Tax Administration Act) but for the due diligence defence (under s. 24.0.2), Cameron JCQ found that Delia had taken reasonable steps “in establishing and maintaining a reliable accounting system” (para. 122), that the allegedly erroneous entry only “accounted for around 2.4% of the total gross QST … generated annually on sales” (para. 123) and (at para. 125): …[T]he inability of those at Motostar to substantiate with precision the entry does not in any way establish a lack of diligence, care or skill on the part of the director who had entrusted the accounting and the handling of the tax returns to them. ...