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., both before and after the emigration time) – hence, s. 128.1(4) had no application and the trust avoided capital gains tax on shares held by it with an accrued gain. ...

. … [Furthermore] there was a long period of inactivity, the evidence clearly illustrating that the [pre-AoC] company was at a standstill for quite some time. ...

. … [Furthermore] there was a long period of inactivity, the evidence clearly illustrating that the Pierres Gémo Inc. company was at a standstill for quite some time. ...

Bowie J stated (at para. 13): [O]nly an insurance company licensed to do so may sell insurance, and only a provincial government may sell motor vehicle licences… Vanex Truck Service was distinguished (at para. 17) on the basis that: [W]hat Vanex supplied to the drivers was the right to drive their vehicles with the benefit of licences and insurance for which it had paid … [and] the Appellant does not appear to have advanced an argument based on agency in that case. ...

Attorney General of Canada, 2024 ONSC 1955-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) trust allocation resolution rectified to set out specific amounts After a discretionary family trust realized a capital gain from a share sale, the sole trustee passed a resolution in that year providing that “[t]he income of the Trust be allocated to the [three stated] Beneficiaries of the Trust payable by way of demand Promissory Note in such amounts to be determined when the income of the Trust is ascertained ….” ...

Before concluding (at para. 382) that “the taxpayer has established that the prices that CMPL was paid by GIAG for the copper concentrate it supplied to GIAG under the February 2007 Agreement were within an arm’s length range” (and before quoting, at para. 325, with approval the statement in Cameco that “The traditional transfer pricing rules must not be used to recast the arrangements actually made among the participants,”) Davies J stated (at paras. 181, 313-314): In the present case, the relevant mine producer for the purposes of the hypothetical [arm’s length] agreement is a mine producer with all the characteristics of CMPL, which include … that it had no need for a logistics or marketing division because it sold the whole of its production for the life of the mine to a buyer with GIAG’s characteristics, namely a trader with a substantial marketing team which purchased the whole of the mine’s production for the life of the mine. … The taxpayer argued that the Commissioner’s approach, rather than pricing the copper concentrate as sold under the actual agreement that was in place between the related parties, required the Court to engage in a speculative task of re-imagining all of the terms of the contract to which independent parties might be expected to have agreed, including by: converting a contract that applied for the whole of the 2007 to 2009 period, with no facility for annual renegotiation, into one that was renegotiated annually; replacing the price sharing basis of the actual agreement with a TCRC provision set by reference to the Japanese benchmark; and replacing the quotational period optionality with back pricing under the actual agreement with a different quotational period provision. ...

. … Once the general operation of the GST Act is understood in that way, it is apparent that there is no warrant in the text or policy of the GST Act for reading the reference in the special rule in s 40-35 to a supply of "residential premises" that is a supply "by way of lease" as referring to the supply which occurs at the time of entering into the lease but not as referring to the further supply which occurs by means of the lessor observing and continuing to observe the express or implied covenant of quiet enjoyment under the lease. ...

Although Mehjoo was resident in the UK, he might have been able to utilize a bearer warrant scheme ("BWS ") to avoid capital gains tax on his sale of shares of a UK private company on the basis that he was domiciled outside the UK. ...

" Similarly, Lord Millet stated (at 418 WLR): Once the taxpayer has identified the payment the question to be asked is: did he obtain anything- anything at all – used or to be used for the purposes of his business in return for that payment? ...

In finding that the deferral was not available, Feldman J.A. stated (at para. 16): The deeming provision in subsection 1(3) of the Securities Act states how "control" is defined for the purposes of the LTTA – on the basis of majority voting rights. ...