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Before finding that the memo was potentially relevant and should be produced, St-Hillaire J noted that there was no accountant-client privilege, stating (at para. 59, TaxInterpretations translation): According to the appellant, if such advice were to be systematically disclosed, the quality of communication between accountants and their clients, and compliance with the Act would be reduced …. ...

Here, regarding s. 6(1)(b)(vii) “its wording requires that the employee be travelling away from the employer’s establishment … [whereas h]ere, Burnaby City Hall has no connection to the employer’s establishment so the allowance received by Mr. ...

. … The doctrine of paramountcy, as argued by the appellants, cannot be engaged in the absence of conflict between the two provisions. ...

. … The Applicant never sent a Notice of Objection for the 2018 taxation year in a timely fashion. ...

Gestion Roy was the owner of such policies (entitling it to the cash surrender value of the policies at any time), so that it was “enriched” when the premiums were paid by R3D (with Boivin JA stating in this regard, at para. 6, TaxInterpretations translation, that “the appellants received an advantage in that for years they owned policies with a total death benefit of $20,000,000 and all the rights attached to them, without having to pay premiums”) – and it was irrelevant to this point that, in fact, Gestion Roy never received any distribution on its policies. ...

. …. And adjusting the quantum of a given penalty would be beyond the jurisdiction of this Court. ...

… [N]either party is bound by their approach prior to the court appeal. ...

. … The facts of Mr Arrbab's case are an unfortunate illustration of the reality that only a right of recourse to an independent tribunal may provide effective protection against failures of administration, including a failure to recognise that time ought to be extended. ...

C.R. 1, should accordingly read: … if there is an expenditure which would be made in any case, from which [income] may accrue, the expenditure may be deducted; but an expenditure which will not be incurred unless there is [income] is not an expenditure in order to earn [income]. ...

St-Hilaire J found (at para. 60) that the relevant part of the Reply “may prejudice the fair hearing of the appeal and is an abuse of process” and should be struck – but with leave to the Crown to amend its pleadings. ...