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In finding that there were two supplies under ss. 142(1)(d) and 142(2)(d), respectively, Dawson JA stated (at paras. 95, 97): I see no reason in principle that precludes splitting up the supply so that the supply is treated as two supplies in order to recognize that ultimately the services are inherently distinct in one important respect: the services relating to the operation of the vacation homes located in Canada are services in relation to real property situated in Canada and hence are a taxable supply – the services relating to the operation of the Intrawest vacation homes situated outside of Canada are services related to real property situated outside of Canada and hence are a non-taxable supply. ...

Fournier JCQ found (at paras 62, 66, 73-76, TaxInterpretations translation): The RCA proceeds paid to Teitelbaum in 2010 were … a right or property that was part of the estate of Lewin at the time of his death and for which the executors of the estate should have taken possession from its commencement…. ...

. … I believe it was reasonable for the Minister’s Delegate to conclude that a CRA agent would seek to follow up with the Applicant regarding its obviously missing T1135 return.” ...

Since the payment of the sums … to the City of Chandler had the effect of freeing the appellant of its obligation to negotiate in good faith to create a limited partnership, the consideration received by the appellant in exchange for such payment was the amount by which that obligation was extinguished. ...

Section 97 uses the phrase “immediately after... the partnership... acquired the property” in subsection 97(1) …. ...

. … [T]he Notes… are investments by SLT in debt instruments of BNSIL and TDII, which are non-resident entities. ...

It does not embrace a share that, in the event of a reduction or redemption of capital, does not give its holder the right to participate in the corporation's assets …. ...

Accordingly, the plaintiffs had not met the first requirement for a mandamus order (the existence of a legal obligation of a public character) – nor had they demonstrated that the Minister’s decision was unreasonable. ...

The MGICs were also the sole members of a non-share corporation (“Groupe Promutuel,” or the “Federation”) which did not have any capital participation in ProRé, and whose affairs were administered by a board of directors consisting of 10 individuals – seven directors and three managing directors of different MGICs. ...

Before granting the amendments, D’Auray J indicated that Rule 132 applied only to “formal admissions” such as in pleadings Andersen Consulting ([1998] 1 FC 605 (FCA)) had established “that an application for leave to withdraw admissions did not require a separate form” (para. 75), so that the requested amendment to the Reply could constitute application to withdraw an admission In Burlington’s examination for discovery of the Crown’s nominee in 2014, “[n]umerous times the respondent’s counsel stated that it was the respondent’s position that no amounts were payable as guarantee fees” (para. 77) Although in an Amended Reply, the Crown had admitted that guarantee fees had been paid in the amounts stated in the Notice of Appeal, “the respondent did not make a clear and deliberate concession that the amounts paid to BRI were guarantees fees” (para. 80) in light of the point immediately above and denials made by the Crown elsewhere in the Reply Even if there had been such an admission, D’Auray J “would still have permitted the withdrawal of the admission since … there is a triable issue which ought to be tried in the interests of justice” (para. 82) “In addition, the purported withdrawal does not amount to an injustice to Burlington since it has been aware of the respondent’s position at least since its discovery of the respondent’s nominee in 2014.” ...