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. … The submission, dated two weeks after the notice of reassessment, while not perfectly detailed, was sufficient to initiate the objection process responsive to an audit and conclusions already in active dispute. … The Minister has not considered the objection as she should have done. … ...

See summaries under Public Service Body Rebate (GST/HST) Regulations, s. 2 – government funding, Sched. ... II, s. 1 – home care services. ...

. … In respect of Fourney, control of Qun was “manifested in the authority” Kwong and Yu-Lian gave her in buying and eventually selling the Markham property for them.... An implied agency simply reflects existence of an agency relationship in the absence of formal or explicit documentation identifying that agency relationship. … Actual conduct rather than existence of formal agency agreement normally governs [a finding of implied agency]. … It was Kwong who obtained the benefit of the Rebate. … The Rebate application was not made by Qun...on her own behalf but rather by her in her capacity as agent for...Kwong…he being titular owner of the Markham property …. ...

Lafleur J rejected an argument that “on the basis of Hickerty, [2007 TCC 482] that where an appellant has taken positive actions to appeal and where that appellant reasonably believes that the appeal has been validly filed, the one‑year grace period had stopped running,” stating (at paras 75, 77 and 84): The Federal Court of Appeal in Carlson … made it clear that the one‑year grace period is strict and cannot be waived. … In view of the doctrine of the Federal Court of Appeal, the fact that the Appellant did not realize before August 2016 that the 2002 Reassessment was not appealed from can have no impact whatsoever on the calculation of the one-year grace period. … The fact that the CRA was mistakenly under the impression that the 2002 Reassessment was being appealed from and did not start collection proceedings before 2016 has no bearing on that conclusion. … The wording of section 167 and paragraph 167(5)(a) of the Act is clear and unambiguous; the language of this paragraph does not allow me to conclude that the time stopped running because the Appellant was under the wrong impression that the 2002 Reassessment was being appealed from. ...

. … What occurred was a revocation, it would appear on an unsolicited and unobserved basis, of the company’s territorial licence to operate in Macao. ... …In effect, the existing business and inventory became stranded and almost valueless because of hugely impactful legislative change. … Further, there was no authority for Mr. Groscki to act as liquidator. … Some instrument or action must award or grant some authority or at least “colour of right” to “administer assets” in the course of a dissolution, winding up and/or liquidation. … He went on to find (at para. 70) that, even if the appellant had been a legal representative, he was not in “possession and control” of EMI Macao’s property, stating that such control was instead in the hands of a related distributor corporation. ...

. … The wording of the provision is unambiguous …. ...

. … Ikea did not overrule Firestone or Neonex. Rather, it emphasized the purpose test. … The Supreme Court has endorsed the principle that the underlying purpose of an expense must be considered in the context of the taxpayer’s business. …[T]he expenses … [Mr. Robinson] incurred, put in the most favourable light, are expenditures relating to the acquisition or creation of a business, not the running of a business. ...

The Queen, 2022 TCC 13-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) MacDonald established that s. 84(2) applied to a speedo pipeline – but correctness of MacDonald doubted The taxpayer, an estate which received shares of a portfolio company (“Holdco”) whose adjusted cost base had been stepped-up under s. 70(5), engaged in some preliminary transactions to access the capital dividend account and refundable dividend tax on hand account of Holdco and then, engaged in post-mortem pipeline transactions under which: On January 17, 2013, the estate transferred its Holdco shares to a newly-incorporated corporation (“9272”) for a note equaling the ACB and fair market value of such shares; On January 18, 2013, Holdco was wound up into 9272. 9272 repaid the note on February 8, 2013. After noting (at para. 20, TaxInterpretations translation) the Crown submission that “the transactions of the estate were almost identical to the transactions in the MacDonald decision,” Hogan J found (at para. 23) that under the “rule of stare decisis … whether or not I agree with the FCA's reasoning in MacDonald … I am bound by the FCA's findings.” ...

In dismissing the taxpayer’s appeal, Favreau J stated (at paras 26, 28): The Convention between Canada and Australia … does not prohibit the taxation of the pension benefits by Canada. … [T]he amounts received by the Appellant from the QSuper were superannuation or pension benefits and that they had to be included in his income in accordance with subparagraph 56(1)(a)(i) of the Act regardless that he was unable to deduct the contributions to the QSuper when he made them. ...

. … The standard imposed by paragraph 298(4)(a) is not one of perfection. … [T]he mistake made by Mr. ...