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Nonis continued to be an employee after his “termination” (albeit, with virtually non-existent duties), Bocock applied the principle (at para. 59) that, under “paragraph 4(1)(b) of the Act, if a taxpayer works partly in Canada and partly in another country in the same taxation year, the taxpayer’s taxable Canadian income for the year is the amount earned while working physically in Canada” – so that Mr. ...

., the expectation “that judges will consider the decisions of their colleagues carefully and, if they choose to differ, will explain why … is not a basis for appellate intervention.” ...

. … While section 54 ensures that stock option benefits are subject to sections 49 et seq. of the T.A. and excludes them from the scope of sections 36 and 37 [equivalent to ITA ss. 5, 6], it is not, in the absence of clear legislative indications to that effect, a code so complete and airtight that the application of section 422 is excluded. ...

These transactions depended in part on the appellants being considered to have acquired units of an income fund ("FMO") from another income fund ("TOM") (which in turn had purportedly acquired the FMO units from an RRSP in consideration for issuing TOM units to it) at a cost equaling the units’ FMV, followed immediately by a distribution to them of capital gains that had been realized by FMO – with that distribution not reducing the ACB of their units by virtue of s. 53(2)(h)(i.1)(A) and (B)((I). ...

These transactions depended in part on the appellants being considered to have transferred the acquired units of an income fund (“FMO”) at a cost equaling the units’ FMV followed immediately by a distribution to them of capital gains that had been realized by TOM – with that distribution not reducing the ACB of their units by virtue of s. 53(2)(h)(i.1)(A) and (B)((I). ...

Before confirming the ARQ view (and reversing the decision below), the Court noted that the daughter was not subject to Quebec income tax, referred to the Oceanspan decision as being “particularly illuminating” (para. 44, TaxInterpretations translation), and further stated (at para. 45): The Oceanspan decision was recently cited … in the Marino decision. ...

(c) exclusion also did not apply, Bourgeois JCQ stated (at para. 44, TaxInterpretations translation): The acquired goods were used exclusively for the handling of materials already collected by the cable excavator, in the context of operations necessary for washing, sorting and crushing and then stacking the various products intended either to be sold to third parties (as to 73.3%) or to be used by the plaintiff (as to 26.67%) …. ...

. … The ARQ correctly argues that it is undisputed in several respects that the award in question was intended to compensate the plaintiffs for an injury directly resulting from the loss of their employment. ...

After having noted that the word “document” (used in s. 288(1)) was defined in s. 123(1) to include “a record” which, in turn, was defined to include “any other thing containing information, whether in writing or in any other form ” (her emphasis), she also rejected (at para. 22) the contention of Tellza that “the request for records in an electronically readable format, along with the system administrator’s user ID and password, where applicable, falls outside the scope of the inspection power in the ETA s 288(1).” ...

Before concluding that 9267 was not entitled to the s. 231(1) credit, D’Auray J stated (at para. 42, TaxInterpretations translation): … 9267 did not remit GST on the taxable supply, i.e., on the sale of its domain names to 9210, when it filed its return. ...