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. … The Corporation should have taken steps to ensure that any amounts received as Rebates, regardless of form, were properly accounted for and reflected in its books and records. ...

Although CRA had suspected that the Samaroos had failed to provide the “till tapes” for one of the daily shifts to the corporate bookkeeper, Harris JA indicated that the trial judge had erred in considering “proof of the till tape theory, a particular scheme, as essential to proving the actus reus ” of the alleged s. 239(1)(d) offence (para. 57)- whereas, in fact (para. 58): [T]he actus reus of the offence does not depend on proof of any particular method by which taxable income is not reported. ...

. … [and] that directors and/or shareholders may make a decision and act upon it, even though they may not record that decision in writing until a later date. ...

. … The focus of [s. 20(1)(c)] is the current use of the borrowed money, not on the current ownership status of the property initially acquired with it. ...

As subsection 123(1) makes clear, this exceptional treatment is restricted to non-resident insurers …. ...

Before so finding, he stated (at para. 29): … I am not convinced that section 53 of the Rules, respecting the striking of pleadings, is the equivalent of a rule permitting the Court to render a summary judgment. ...

Before concluding that the ARQ had not exceeded its territorial competence in making this requirement, Rowe J found that the sending of the requirement to the Calgary branch (which was deemed to be a separate entity only for the limited purposes of s. 462)) did not detract from the fact that it was sent to a person (the bank) that operated in Quebec, stating (at para. 88): It would be absurd if the procedural requirements imposed by s. 462(2) … were understood to affect the ARQ’s authority to issue a formal demand to a bank that operates within its territorial jurisdiction. ...

… I cannot imagine why in a case such as this the CRA would prefer to have Mr. ...

Sommerfeldt J stated (at para. 49): … [A]s 137ON was still endeavouring to obtain the requisite approvals to construct a storage container facility on the Subject Property, it had not yet begun to use the Subject Property in the course of its commercial activities. ...

Accordingly … each of the Invoices, by specifying the amount of the fee to be paid, with the implied requirement that the fee be paid in cash within a reasonable time, has satisfied the requirement in subparagraph 3(c)(iii) to set out the terms of payment. ...