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After noting (at p. 5016) that the issue was whether there was a “clear and unequivocal positive act” to implement a change of intention so as to “indicate a change in the character of the homestead property from a capital asset to a trading asset,” McNair J. held that a change in use from capital property to inventory did not occur until 1976, which was the year in which "the family held the first official meeting of shareholders to discuss what should be done with the … property" (p. 5014). ...

. … [T]he oral sublease between the plaintiffs and [the corporation] eliminates any element of doubt that the net effect of the whole transaction was to transfer the head lease and the gallonage payment rentals to the corporation, notwithstanding that there was not express formal assignment of the head lease itself. ...

Before reaching this conclusion, Joyal J. stated (p. 6282) that: "... although a profit, expressed in percentage terms as a return on investment, on energy and time and effort expended, might not be of a nature to invite a take-over bid..., the test of reasonableness is met if a profit has been realized. ...

Before reaching this conclusion, Joyal J. stated (p. 6282) that: "... although a profit, expressed in percentage terms as a return on investment, on energy and time and effort expended, might not be of a nature to invite a take-over bid..., the test of reasonableness is met if a profit has been realized. ...

. … Moreover, subsection 220(2.1) specifically enables the Minister to request a document that has been waived. ...

Two of the four main Canadian cigarette companies (MacDonald, and Benson & Hedges) proposed to introduce a cigarette having an overall length including the filter tip of over four inches, but with the tobacco portion less than four inches. ...

. … In any event, I agree with the CRA’s interpretation that financial hardship for an individual is financial suffering or lack of what is needed for basic living requirements, such as food, clothing, shelter and reasonable nonessentials. ...

CRA assessed late filing penalties under s. 162(7)(a) respecting the late T1135s – and then, on a second-level review, cancelled the penalty for 2012 but not for 2011. ...

CRA assessed late filing penalties under s. 162(7)(a) respecting the late T1135s – and then, on a second-level review, cancelled the penalty for 2012 but not for 2011. ...

In those cases, denying the defence would give rise to the concerns mentioned by Justice Iacobucci at para 44 of First Vancouver – it "would have a general chilling effect on commercial transactions.” ...