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Before so finding, he stated (at para. 29): … I am not convinced that section 53 of the Rules, respecting the striking of pleadings, is the equivalent of a rule permitting the Court to render a summary judgment. ...

… I cannot imagine why in a case such as this the CRA would prefer to have Mr. ...

Sommerfeldt J stated (at para. 49): … [A]s 137ON was still endeavouring to obtain the requisite approvals to construct a storage container facility on the Subject Property, it had not yet begun to use the Subject Property in the course of its commercial activities. ...

Accordingly … each of the Invoices, by specifying the amount of the fee to be paid, with the implied requirement that the fee be paid in cash within a reasonable time, has satisfied the requirement in subparagraph 3(c)(iii) to set out the terms of payment. ...

The spin-off mechanics were conventional, and at their conclusion, there were two promissory notes for $30M owing by Oldco and Newco to each other – which then were set-off. ...

The Queen, 2019 TCC 156-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract debt is obligation to pay a sum certain or amount reducible to sum certain After quoting (at para.55) the statement in Sattva that “While the surrounding circumstances are relied upon in the interpretive process, courts cannot use them to deviate from the text such that the court effectively creates a new agreement,” Owen J found that, contrary to the taxpayer’s understanding of the arrangements as reflected in its financial statements, the arrangements at issue had not in fact been structured so as to give rise to a debt owing to the taxpayer by a corporation that subsequently became bankrupt – so that the taxpayer’s claim for a business investment loss was properly denied. ...

Wall’s false statements or omissions were blatant and readily determinable …. ...

However, given that the test set out … in Hickman... is still applied by the Courts. ...

Although many of the receipts issued by the Apple stores had missing, scratched, fictitious or unreadable names for the buyers (as agents of Lohas), for the transactions where a bank draft was issued to a buyer, a “memo prepared by Lohas showed the name of each buyer, the iPhones purchases, the tax and the commissions paid” (para. 147) However, for the transactions that Lohas paid in cash, the memo did not always indicate the name of the buyers – and, as noted, the receipts were defective- so that ITCs were denied for these, but not for those where the names were noted in the memo. ...

. … Should the Minister decide to exercise her discretion under subsection 207.06(1) of the Act to cancel the Appellant’s liability in respect of the inadvertent deposit of $40,000 to his TFSA on the night of July 21, 2016, such cancellation would find ample support on the extraordinary facts of this case. ...