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This provision would have deemed the shares of Alta Canada to be immovable property (thereby permitting the gain from their disposition to be subject to Canadian capital gains tax) on the basis that they derived their value principally from immovable property situated in Canada, subject to an exclusion which deemed the underlying licences not to be immovable property if they were property of Alta Canada “in which the business of the company … was carried on.” ...

Paletta International reported a loss of US$96.1 million from the partnership, which mostly related to its share of the P&A expenses – and also reported a capital gain from the disposition of its partnership units (but took advantage of the 5-year capital gains reserve.) ...

. … The Crown has not persuaded me that in 2008 and 2009 the purpose of the Reduction Provision was to do anything other than to reduce the addition of life insurance proceeds to a corporation’s capital dividend account by the amount of the adjusted cost basis of the life insurance policy to that corporation. ...

Monaghan J stated (at para. 213): … The Tax Court will address all challenges to the correctness of the assessment made after the transfer pricing provisions have been applied, including whether the conditions for their application are met, the amount of any adjustments, the liability for penalties and whether the Minister exercised her discretion properly. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...

. … If the Minister agrees with Mr. Turski, and indeed with me, that the application of the 36-month rule in this case seems to lead to an unfair and unreasonable result, and that the public interest that led to the adoption of that rule does not apply in this case- and I hope the Minister will so agree- then the Minister will ask Cabinet to approve the remission order. ...

. … I [also] do not believe it is in the public interest that I decide on an issue without hearing evidence that is relevant to the determination as to whether or not the exclusions apply. ...

. … There is a direct link between the PCB Points that are issued in conjunction with an exempt financial service supplied by PC Bank to Cardholders and an expense that is paid when the PCB Points are redeemed by Cardholders. ...

. … In this case, the appellants could revoke the designation of R3D as beneficiary at any time, but this is a right that flows from the insurance contract. ...

He accepted (at para. 26) the “frustrating event” doctrine from Sazio (2018 TCC 258), but stated (at para. 26): To invoke frustration, the surrounding circumstances must make the frustrating event unforeseeable, beyond the buyer’s control, and deny the buyer any alternative pathway to having the property be their primary residence …. ...