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CRA assessed him advantage tax under s. 207.05 equalling 100% of the appreciation of the shares within his TFSA before the shares’ sale – and following a Federal Court action by him, proposed to reduce the rate of advantage tax to his marginal federal and provincial tax rate. ...

In confirming this assessment, Owen J found (at para. 127): … Since the pharmaceuticals were not (and could not be) imported into Canada for sale, the approach to valuation adopted for the CGI Program is patently flawed since it is using a Canadian market (Ontario) to value generic pharmaceuticals that cannot be sold in that market. ...

After noting (at para. 65) that “the information required by subsection 169(4) … may be contained collectively in multiple documents,” Sommerfeldt J noted that whether s. 3(a)(ii) or (iii) of the Input Tax Credit Information (GST/HST) Regulations applied turned on whether DCML had issued an invoice to the appellant. ...

After noting that essentially noting (at para. 45) that “the Tendances et Concepts case may not carry as much weight now, given that it was based on a previous French version of the ETA, in which arrhes was used as the French equivalent for the English deposit ” and that (notwithstanding North Shore Power) IHI’s making of interim payments could have been consistent with their being deposits, Sommerfeldt J stated (at para. 54): [T]he payment structure set out in [the] email of December 7, 2007 has a broad similarity to the payment structure in North Shore Power. ...

. … To ignore the construction component of the Appellant’s business would be an incorrect interpretation of the phrase “derived primarily from”. ...

Before granting the taxpayer’s appeal from the assessment, Favreau J first indicated that the Crown was not bound by the Court order “as neither the Attorney General of Canada nor the Minister was involved in the application” (para. 59), and also found that the judgment was not “ res judicata.” ...

. … In my view, when the appellants’ RRSPs acquired the undivided interests in the Zowtra Mortgage the relevant RRSPs acquired an interest in a mortgage, that is, an interest in “a charge on land created... for securing a debt or loan”. ...

Moreover … the Court does not make decisions on the basis of fairness.... ...

. … The Corporation should have taken steps to ensure that any amounts received as Rebates, regardless of form, were properly accounted for and reflected in its books and records. ...

. … [and] that directors and/or shareholders may make a decision and act upon it, even though they may not record that decision in writing until a later date. ...