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For the current year, she filed her regular return about seven weeks late after claiming to have confirmed on the CRA General Inquiries line that there would be no penalty for doing so (as no Part I taxes were owing) but filed her T1135 return with that return – and was assessed a late-filing penalty under s, 162(7) for late-filing the latter return, of $25 per day (or $1225 in total) plus interest. ... She also accepted (at para. 20) the CRA view (summarized at para. 9) that: Without her documents (her being in Toronto and not Fredericton) … she could have instead filed an estimated 2015 Form T1135 and then amended it once she had her documents. ...

In this regard, Rivoalen JA quoted the statement of the Tax Court (at para. 55 of its reasons) that “there was no evidence that the Appellant actually ceased to be a resident of the Netherlands or was continued under Canadian law,” and stated (at paras. 19-20): [S]ubsection 128.1(1) … provides only for the consequences of a taxpayer becoming resident of Canada. There is no additional requirement that the taxpayer must cease being a resident of its former State …. ...

Agence du revenu du Québec, 2019 QCCQ 6956, rev'd 2021 QCCA 1050-- summary under Paragraph 8(a) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(a) a building for warming equipment qualified as “manufacturing or processing machinery or equipment” The taxpayer, whose business entailed the bending, cutting and assembly through soldering of metallic equipment such as junction boxes, gutters and truck boxes mainly for mining customers, leased space for a nominal rent at the remote northern site of one of its mining-company customers (AM) in order that it could assemble such items (which were quite bulky – e.g., 5 tonnes) on site. ... The Econox also was fixed equipment which permitted the plaintiff to manufacture and process industrial and mining items. … In default of being able to speak of permanent physical integration, one can certainly speak of a functional integration as the plaintiff could not carry out its operations in the Great North without the Econox. ...

. … [T]he fees incurred pursuing the Oppression litigation had as its dominant purpose, the intention to protect the Appellant’s interest in her shares in the corporations. ... Therefore, I have apportioned the fees in issue. … I will make an estimate that 25% of amount paid in the Oppression litigation was incurred in order to receive income. ...

In the current context … the absence of a software, search engine or substantial electronic disclosure management system does not meet the test of reasonable accessibility. … [T]he defendant has established, on a balance of probabilities, that there are specific deficiencies or significant technical difficulties with the disclosure of the evidence in electronic form. ...

The Queen, 2020 TCC 33 (Informal Procedure)-- summary under Paragraph 8(1)(b) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(b) s. 8(1)(b) did not cover legal costs of an action to extend the period of employment The taxpayer worked as a provisional judge for the Montreal Municipal Court up until 2005, and then served as a full-time judge up until 2012, at which time he was forced to resign as he had attained the age of 70 – which meant that he was 23 months short of the requisite years of full-time service required to generate a full pension. ... Clément was instead seeking was the right to hold his office beyond the age of 70 and to be reinstated in his office so that he could accumulate credits for his pension. … Respecting the second ground, she stated (at para. 29): If Mr. ...

The ARQ assessed Grands Palais on the basis that the consideration paid by 93 of the purchasers for their “single unit residential complex” included the parking spot purchased by them at the same time (viewed by the ARQ under the “residential complex” definition as being “attributable to the unit and … reasonably necessary for the use and enjoyment of the unit”), so that such total consideration exceeded the maximum $300,000 permitted consideration for purposes of the new housing rebate (pursuant to s. 362.2 of the Quebec Sales Tax Act). ... There are 408 of them, and they exceed the total number of residential units held in divided co-ownership that make up the real estate project. … The location of the various high-rise residential buildings and the advantages that indoor parking spaces can provide led 99.44% of purchasers to express their intention to acquire at least one parking space at the same time as their residential unit. ...

In particular, she found that the parking spot was “attributable to the [condo] unit and … reasonably necessary for the use and enjoyment of the unit,” stating (at paras. 63, 65, TaxInterpretations translation): The location of the various high-rise residential buildings and the advantages that indoor parking spaces can provide led 99.44% of purchasers to express their intention to acquire at least one parking space at the same time as their residential unit. [A]lthough they constitute different cadastral lots … the interdependence and interconnection of the parking spaces to the residential units are such that they could not be considered, for the purposes of establishing the amount of the Rebate to which the purchasers were entitled, as separate components. ...

. … Even if the supply provided by Zomaron to the Processors involved services of a promotional nature, since these do not represent the predominant element of the supply, paragraph (r.4) has no application …. ...

ITA 231.2(3) and ETA s. 289(3) for Roofmart to disclose various particulars for all of its customers who in the past 4 ½ years had made purchases of construction materials from Roofmart exceeding specified dollar thresholds. ... He further stated (at para. 39) that the “fact that the UPR may target an unspecified or large number of accounts or that a significant amount of financial information may be captured does not affect its validity,” and (at para. 45) that “ GMREB established that a pending or existing tax audit of a particular individual is not a precondition to the exercise of power under subsection 231.2(3).” ...