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. … The facts of Mr Arrbab's case are an unfortunate illustration of the reality that only a right of recourse to an independent tribunal may provide effective protection against failures of administration, including a failure to recognise that time ought to be extended. ...

C.R. 1, should accordingly read: … if there is an expenditure which would be made in any case, from which [income] may accrue, the expenditure may be deducted; but an expenditure which will not be incurred unless there is [income] is not an expenditure in order to earn [income]. ...

St-Hilaire J found (at para. 60) that the relevant part of the Reply “may prejudice the fair hearing of the appeal and is an abuse of process” and should be struck – but with leave to the Crown to amend its pleadings. ...

Of the factors listed in Rule 147(3), those arguing for increased costs were: the costs at issue ($2.2 million for the taxation year at issue, similar amounts for two other taxation years, and $10 million in a number of related appeals); the complexity of the issue (including taking into account reported proceedings in Deans Knight, requiring the parties to “regularly … rework their arguments” (para. 14); and the taxpayer’s failure to concede until oral argument that there was an avoidance purpose for the creation of Class C non-voting shares. ...

Nonetheless, the Crown did not agree to be bound by those findings until the eve of trial – and this delay in following BC Ferries caused the Appellant to incur substantial costs. ...

(para. 48) “[T]he transactions were structured in the way they were to benefit Corco … [which] needed a way to finance the purchase.” ...

An RVO advances the same goals as an AVO — albeit by employing a different transaction structure. ...

By committing itself to issuing 1,380,000 shares to a trust for the benefit of all eligible employees, the Company failed to meet the requirements of subsections 7(1) and 7(2) …. ...

By committing itself to issuing 1,380,000 shares to a trust for the benefit of all eligible employees, the Company failed to meet the requirements of subsections 7(1) and 7(2) …. ...

. … [T]he fair market value of a business as a going concern plays no role in determining the proceeds of disposition, or consequential recapture, of depreciable property under the Act. ...