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In rejecting their submission (at para. 8) “that 201 was merely a conduit for their money” so that (similarly to Borys) 201 had received the funds from them on behalf of Dandy, Graham J drew an adverse inference from their failure to call a key witness, and noted (at para. 10) and that, during the audit “the Appellants reiterated that their loans had been made to 201” and it” was only when their claims were denied that the Appellants first raised the idea that they had actually lent money to Dandy or Indiva [the other small business corporation]” (para. 12) Graham J concluded (at para. 30): … Had they structured their affairs differently, they may have been successful in claiming ABILs, but in tax law form matters. ...

The Queen, 2022 TCC 13-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) s. 104(6) permitted the deduction of an amount initially treated as a capital distribution An estate engaged in accelerated pipeline transactions in which it transferred shares (stepped up under s. 70(5)) of a portfolio company (“Holdco”) to a Newco in consideration for a note, with Holdco being wound up into Newco a day later – and with the note being repaid by Newco to the estate about three weeks later. ...

(r.4) and (r.5), and further stated (at para. 67): The judgment … rendered [in the 2009 Decision] now hangs by a thread because of the new financial services definition. ...

. … A reasonable person in the same circumstances as Mr. Procopoudis may well have concluded that the position of the Appellant was clear-cut, that the position of the CRA auditor was incorrect and that professional advice was not required. ...

" [emphasis added] … Similarly, according to the OECD Model Commentary on Article 23, the use of the phrase "may be taxed" in a Contracting State in an Article of a tax treaty does not confer an exclusive right on that Contracting State to tax income, unlike the phrase "may be taxed only" in a Contracting State (paras. 6 and 7). ...

However, the taxpayer (a Canadian resident with a French rental property), like others, was granted transitional relief so that in 2019 he received a tax credit from the French government equal to the French tax otherwise payable by him on his 2018 income – so that in 2019 he only had to pay the current tax on his 2019 rental income. ...

. … I see nothing in the text of paragraph (r.3) that suggests that a service that consists of processing authorization requests via an automated system as agent for the issuer of a credit card is excluded under paragraph (r.3). ...

Accordingly, even in the case of the lower threshold for a penalty under s. 162(7)(a), “the defence of due diligence has been established – that is, the appellant reasonably believed in a mistaken set of facts that if true would have made his act or omission to act innocent.” ...

In rejecting the position of the Crown that “nowhere was it written that the appellant was required to incur the recruitment expenses” (para. 21), St-Hilaire J stated (at paras. 30, 31, TaxInterpretations translation): [T]he employer's answer to question 1 on Form T2200 indicated that the appellant was required to pay the expenses incurred to perform the duties related to her work …. ...

Russell J indicated that Kuchta might technically be a nullity (because, as indicated in the comparable High-Crest decision, it had been decided by a substituted judge), but also indicated (a para. 42) that in Kuchta, “Graham, J. properly and diligently applied the textual, contextual and purposive analysis specified by … Canada Trustco in construing the meaning to be ascribed the term ‘spouse’ in paragraph 160(1)(a)” and that, in light of the principle of judicial comity, chose to follow the Kuchta interpretation so as to find that s. 160 applied to the taxpayer. ...