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On the basis of the construction invoices and photos and on the basis of giving the taxpayer the benefit of the doubt by treating “substantially all … as indicating no less than 90%” (para 11), Russell found that the rebate application was submitted more than two years after substantial completion of the renovation project, thus rendering per s. 256(3)(a)(iii) ETA the rebate as not available. ...

The evidence has established that JA is seriously lacking in ability to engage in social interactions … substantially all of the time. ...

Before granting the compliance order, Pentney J cited (at para. 19) Cameco for the proposition that “the fact that the requests may involve substantial documentation which the taxpayer may view as not proportional to the matter is not a relevant consideration,” and further stated (at para. 29): [T]here is no evidence to suggest that the CRA audit has been launched for any purpose other than to ensure compliance with the ETA, or that the request for information was so wide, extraordinary, or unusual as to give rise to questions about its legitimacy in the context of the audit (assuming that such a claim could be brought, in the face of the wide authority granted to the Minister to set the timing, scope, and nature of the audit …). ...

. … The Tax Court Judge was not bound by any admission that CIBC was paying for Aeroplan Miles in light of the agreement, which was properly tendered as evidence at the Tax Court hearing, and which clearly states that the payments made by CIBC were in consideration of Aeroplan “referring or arranging for Aeroplan Members and other members of the public to make Card Applications”. ...

. … The Tax Court Judge was not bound by any admission that CIBC was paying for Aeroplan Miles in light of the agreement, which was properly tendered as evidence at the Tax Court hearing, and which clearly states that the payments made by CIBC were in consideration of Aeroplan “referring or arranging for Aeroplan Members and other members of the public to make Card Applications”. ...

. … I cannot find that the loan was repaid before the end of Steel's 1988 taxation year. ...

. … Evidence contradicting the taxpayer’s arguments included: Each house was listed for sale before the occupancy permit was obtained. ...

. … However, the self-supply rules do not apply if the conditions as set out in subsection 191(5) of the ETA are satisfied. ...

. … Vavilov recognizes the shortcomings in the former law and fixes them. ...

It was only in 2012 when Vocan started to supply assessment reports to Misir & Company, a personal injury law firm that informed Vocan that HST should be charged and collected on their reports, that Vocan then resumed charging insurance companies HST for assessment reports in the 2012 Period. ...