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It, therefore, seems clear that the appellant was on a fishing expedition. ­­­­­­­­­­­­­­­­­­­­­­­­ ...

Tremblay case, Bédard J found that house-repair invoices, that did not give the house address or describe the precise nature of the work performed (and that were rendered in the name of entities that did not remit the GST), failed to satisfy the requirements of s. 3 of the Input Tax Credit Information (GST/HST) Regulations, so that the appellant’s related input tax credit claims were properly denied – and also found (at para. 25) that “the appellant did not truly acquire the supplies for which it claimed ITCs.” ...

The taxpayer in fact “engaged in no acts of management … let alone any actions specific to a director” (para. 40). ...

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. ...

A previous case had found that generally “dismissal under section 16.2 of the TCC Act carries the same effect as a judgment of dismissal by the Court” – and the action which thus had constructively been decided against them was one in which they could have, but failed to, raised their statute-barring arguments. ...

The Queen, 2009 TCC 588 that: None of [the cited cases], however, support the appellant’s proposition that adjustments to the expenses of a previous fiscal period, and concomitant changes to the income of the employee for a previous year, may be made on a retroactive basis …. ...

In rejecting a taxpayer submission that s. 256(1.2)(f)(ii) should be interpreted as providing only that the affected beneficiaries were deemed to hold 24.99% of the shares held by the trusts, and finding that they instead were deemed by s. 256(1.2)(f)(ii) to hold 100% of such shares (so that the appellant corporations were associated), Lamarre ACJ stated (at paras. 54, 56, TaxInterpretations translation): Nothing indicates that subparagraph 256(1.2)(f)(ii) will not apply if the discretionary share of a beneficiary is limited by the deed of trust …. ...

The Queen, 2018 TCC 85-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) Quebec trusts are considered to be owners of their property for ITA purposes The taxpayers, in connection with arguing (at para. 62) that the reference in the preamble to s. 256(1.2)(f)(ii) to “shares … owned.. by a trust” should be interpreted as referring only to shares that had been earmarked under the deed of trust for the beneficiaries, went on to argue (para. 1261) that, having regard to Art. 1261 of the Civil Code, a Quebec trust was not the owner of the property in its patrimony. ...

In this case, the evidence indicated that, during a relatively short period of time, the appellant was duped by his partners and he was unaware that the corporation was having financial difficulties …. ...