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The Queen, 2015 TCC 138-- summary under Subsection 147(3) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 147- Subsection 147(3) Crown offer of better treatment for one of two years The Crown had made a settlement offer to the taxpayer under which the taxpayer would conced that it was not carrying on an insurance business in Bermuda in 2006, but the Crow would concede that the taxpayer was carrying on business in Bermuda in 2007 – and each party would bear its own costs. ...

D’Auray J noted that this employee had no risk, and Hélie Holdco had no upside as its only assets and liabilities were the prefs and the note, both with frozen values – so that Hélie Holdco essentially was just an accommodation party. ...

. … Given my finding of an offset, the rate is immaterial, however, if such a determination was necessary, I determine the interest rate should be 5.5%, being the rate suggested by the expert. ...

. … [P]aragraph (r.4) will only apply if the service in question is supplied separately from the supply of the financial service that is referred to in any of paragraphs (a) to (i) or (l) of the definition of financial service. ...

. … [T]he sole remuneration which was paid to Mr. Castonguay in 2010 or 2011 was not an “amount paid in addition that which is due.” ...

. … Too many of the expenses incurred in making the sales were missing for it to be possible to state that Oldcastle realized a profit on the sale…. ...

In finding that the appellant had continued to be a “registrant,” so that ss. 171(3) and 200(2) did not apply, Favreau J referenced s. 141.1(3) and stated (at paras 57- 60, TaxInterpretations translation): The sale of equipment following the cessation of normal daily activities is … part of what the ETA terms "commercial activity". ...

. … Words and Phrases credit note ...

However 15 months later, CRA vacated the s. 55(2) assessment of 8231 for reasons that are not explained – so that the only outstanding s. 55(2) assessments were of the corporations (807 and 810) acquired by the purchasers. ...

. … The use of the word “habituelle” in French…makes it even more clear and certain that the use of the word “primary” to qualify “place of residence” in English is not to suggest that the new housing rebate is only available to those who also have at least a second home also used as a place of residence. ...