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The following question was posed under Rule 58: Where the Minister has at all times concluded that no partnership existed, can the Minister issue a valid Notice of Determination in respect of that purported partnership under subsection 152(1.4) …. ...

. … …The facts in Schwartz [for losses arising from the retraction of an employment offer] are too different for the decision to be meaningful to the present inquiry. ...

. … This result would be extremely difficult for the Canada Revenue Agency to audit. ...

In this regard, he noted (at para. 74) the statement in Symes that “Courts will … look for objective manifestations of purpose,” and then stated (at para. 76): [S]ubsequent actions or steps taken by Keybrand or [its parent] BWS could be used to either confirm or contradict Keybrand’s stated purpose in borrowing the funds to acquire the shares of Vidabode. ...

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The Court, in Canadian Council, goes on at paragraph 39 to state “[…] most internal documents that analyse a problem, starting with an initial identification of a problem, then canvassing a range of solutions, and ending with specific recommendations for change, are likely to be caught within paragraph (a) or (b) of subsection 21(1)”. ...

Since the TCC’s enhanced cost order (under Rule 147(7)) was wholly contingent on the order it made in the underlying action, when that order was reversed, its Rule 147(7) order was rendered a nullity – there was nothing for the Crown to appeal. ...

In finding that ss. 128.1(1)(b) and (c) did not apply, Smith J stated (at para. 35): [T]he effective date upon which the Appellant became a resident of Canada … was when the Canadian dairy farm was acquired on June 15, 1998. ...

The CRA has already allowed home office expenses of $1,763 for 2012 and $2,333 for 2013 as well as office supplies in the amount of $361.00 pursuant to subsection 18(2) …. ...