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(the “Canadian Resort Point Purchasers” and “American Resort Point Purchasers,” respectively – who also thereupon became member of the Appellant, along with the Canadian and U.S. ...

. … [T]he Appellant, when selling its limited partnership interests in Atria LP and CEC LP to the subsidiaries of AIMCo, clearly took into account the transactions… that resulted in the packaging of the real property into limited partnerships and the bumping of the adjusted cost base with respect to such limited partnerships. ...

. … Parliament…made the positive decision to limit the application of subsection 69(11) to transfers to tax-exempt entities that occur within the three-year period [in s. 69(11).] ...

. … The [wife and children] acquired the shares from the Appellant for a purchase price of $0.01 per share and immediately thereafter sold them for a cash purchase price of $8,645 per share. ...

Finally, Smith J found (at para 58): As indicated… in Kyte … there may be discrepancies as the amounts owed for source deductions may be fluid. ...

. … However, the new replaced area of the roof, half the roof, is inseparable from the floor of the garage below it and from the entire garage. ...

. – of which 3.75% of p.a. was required to be paid annually in cash (“cash-pay interest”) and with the balance was capitalized each year (“capitalized interest”). ...

After rejecting the equivalence of other services of PIC and WSL, he concluded (at para 93): [I]t has not shown that, in the absence of the services provided by WSL and PIC, it would have required more than five full-time employees throughout the years in issue … it carried on a specified investment business in those years. ...

. … I would not expect section 141.01 to deny the input tax credits otherwise determined under subsection 169(1) in the situation where a person is only engaged in commercial activities. ...

. … However, the Appellant argues that it is a resident of the Netherlands where it is domiciled (though no expert evidence was lead on the issue of Dutch law) in which case it is possible to conclude that the Appellant “is a resident of both States”. ...