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Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain, thereby generating Part III tax unless an s. 184(3) election was made. ...

Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain. ...

After noting that the description of the legal services provided had not been revealed to the ARQ on the grounds of privilege, Chalilfour JCQ stated (at paras. 133-135, TaxInterpretations translation): Not waiving professional privilege could certainly render the reversing of the presumption of validity of an assessment … more difficult. ...

He went on to state (at para. 35): …In the alternative, if the supply of the Aeroplan Supplies included multiple supplies, one of which was the separate supply of Aeroplan Miles, … the supply of the Aeroplan Miles was incidental to the supply of promotional and marketing services by Aeroplan to CIBC, such that the supply of the Aeroplan Miles is deemed by section 138 of the Act to be a part of the supply of the promotional and marketing services made by Aeroplan to CIBC. ...

In fact, the quality of the sound recording had everything to do with the quality of the physical medium …. ...

The Queen, 2019 TCC 109 (Informal Procedure)-- summary under Subparagraph 256(3)(a)(iii) Summary Under Tax Topics- Excise Tax Act- Section 256- Subsection 256(3)- Paragraph 256(3)(a)- Subparagraph 256(3)(a)(iii) substantial completion had occurred by the time of the interim occupancy certificate The taxpayer and her husband built a house, which was near Lake Huron and a 2 ½ hour drive from their Brampton rental apartment and full-time employment, doing a large portion of the work themselves on weekends beginning in 2008, with the intention to retire there. ...

Here, although Veracel was the larger corporation, essentially all its assets were the subscription-receipt cash proceeds – and “There was no scenario under which Veracel would have been allowed to retain the money…” (para. 53). ...

By conceding that the interest expenses paid in respect of the loans taken out to finance expenses totalling $62,280... the respondent recognized … that the appellant carried on a business during that period and that the expenses totalling $62,280 had been incurred in relation to his commercial activities. ...

Although it was unnecessary to decide on the further ground for revocation that Many Mansions was engaging in activities inconsistent with its registered object (of “advanc[ing] and teach[ing] the religious tenets, doctrines, observances and culture associated with the Christian faith”), Laskin JA nonetheless stated (at para. 6): Many Mansions submits that judgments on matters of religious doctrine or theology have no place in government …. ...

If the alleged fault of the respondents rested solely on the erroneous collection of taxes on products sold, it could be concluded that the recourse sought attempted to circumvent the ETA and STA …. ...