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It may well be the case … that the error in the tax remittances was not made by the CRA or alternatively …that the Applicants could have filed the NR Returns before the filing deadline. ...

. … A reasonable person in the same circumstances as Mr. Procopoudis may well have concluded that the position of the Appellant was clear-cut, that the position of the CRA auditor was incorrect and that professional advice was not required. ...

. … [G]iven that the appellant did not acquire the services, it could not provide them as in kind benefits. ...

. … Words and Phrases income from property ...

" [emphasis added] … Similarly, according to the OECD Model Commentary on Article 23, the use of the phrase "may be taxed" in a Contracting State in an Article of a tax treaty does not confer an exclusive right on that Contracting State to tax income, unlike the phrase "may be taxed only" in a Contracting State (paras. 6 and 7). ...

However, the taxpayer (a Canadian resident with a French rental property), like others, was granted transitional relief so that in 2019 he received a tax credit from the French government equal to the French tax otherwise payable by him on his 2018 income – so that in 2019 he only had to pay the current tax on his 2019 rental income. ...

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[C]onsistent with Nash … the first step is to identify the property to be valued [i.e., each “condo” unit]. ...

In rejecting this submission, Gleason JA stated (at paras. 15, 24): On its plain meaning, a deeming provision does not constitute an “election” or “appointment” …. ...

. … I see nothing in the text of paragraph (r.3) that suggests that a service that consists of processing authorization requests via an automated system as agent for the issuer of a credit card is excluded under paragraph (r.3). ...