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Such an interpretation would clearly undermine the intent of the Parliament …. ...

D’Arcy J previously had directed that certain of the appeals proceed under the Court’s lead case rules (in Rule 146.1) – there were two lead cases under the general procedure and 23 informal appeals were held in abeyance. ...

In this instance, it is clear that the “prescribed information” required to support the Rental Rebate application was not included with the New Housing Rebate application …. ...

Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain, thereby generating Part III tax unless an s. 184(3) election was made. ...

Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain. ...

He went on to state (at para. 35): …In the alternative, if the supply of the Aeroplan Supplies included multiple supplies, one of which was the separate supply of Aeroplan Miles, … the supply of the Aeroplan Miles was incidental to the supply of promotional and marketing services by Aeroplan to CIBC, such that the supply of the Aeroplan Miles is deemed by section 138 of the Act to be a part of the supply of the promotional and marketing services made by Aeroplan to CIBC. ...

The Queen, 2019 TCC 109 (Informal Procedure)-- summary under Subparagraph 256(3)(a)(iii) Summary Under Tax Topics- Excise Tax Act- Section 256- Subsection 256(3)- Paragraph 256(3)(a)- Subparagraph 256(3)(a)(iii) substantial completion had occurred by the time of the interim occupancy certificate The taxpayer and her husband built a house, which was near Lake Huron and a 2 ½ hour drive from their Brampton rental apartment and full-time employment, doing a large portion of the work themselves on weekends beginning in 2008, with the intention to retire there. ...

By conceding that the interest expenses paid in respect of the loans taken out to finance expenses totalling $62,280... the respondent recognized … that the appellant carried on a business during that period and that the expenses totalling $62,280 had been incurred in relation to his commercial activities. ...

She concluded (at para. 73): [T]he breach justifies the lesser sanction of the Suspension especially since there has been repeated non‑compliance involving receipts for expense amounts for activities outside Canada, it could only account for half of such expenses and the production of documentation and such receipts were not timely and the fact remains that PLM has still not produced all such receipts … ...

She concluded (at para. 73): [T]he breach justifies the lesser sanction of the Suspension especially since there has been repeated non‑compliance involving receipts for expense amounts for activities outside Canada, it could only account for half of such expenses and the production of documentation and such receipts were not timely and the fact remains that PLM has still not produced all such receipts …. ...