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., the identity of the debtor, the principal amount, the amount of interest and the maturity date” identified in General Electric Capital, “ the only term that was significantly different in respect of the Post-Auction Debt … was the amount of interest.” ... The key passage appears to be the following (at para. 86): [S]ubparagraph (b)(i) of the [s. 248(1)] definition of “disposition” … states that “‘disposition’ of any property … includes … any transaction or event by which, … where the property is a … mortgage, … the property is in whole or in part redeemed, acquired or cancelled….” … Thus, by reason of the foreclosure and the judicial sale, the Mortgage was cancelled. ...

Before granting the compliance order, Pentney J stated (at paras 18, 19, 29): … I reject the Respondents’ argument that section 289.1 can only be invoked where a taxpayer has “refused” to provide the requested information…. [T]he provision states that a compliance order may be granted if the Court “is satisfied that (a) the person was required under section 288 or 289 to provide the… information or document and did not do so…” (emphasis added). … … As noted in... ... In addition, the fact that the requests may involve substantial documentation which the taxpayer may view as not proportional to the matter is not a relevant consideration (para 42) … In this case, there is no evidence to suggest that the CRA audit has been launched for any purpose other than to ensure compliance with the ETA, or that the request for information was so wide, extraordinary, or unusual as to give rise to questions about its legitimacy in the context of the audit (assuming that such a claim could be brought, in the face of the wide authority granted to the Minister to set the timing, scope, and nature of the audit …. ...

". … [T]here is no expert evidence as to the value of the Courseware at the time it was donated by the Appellant. … … GLS created a significant market for the multimedia courseware in much the same way as markets were created for art prints in Klotz and Nash. ...

In finding that the rent prepayments were capital expenditures, so that such deduction was not permitted, Jagot J stated (at paras 115, 119 and 125): [T]he payments … were … a one off, lump sum, non-refundable payment made to secure an enduring advantage (the right to pay the lesser percentage rent) for the term of the [leases] and most likely the term of any renewal of the [leases]. ... As a matter of substance the payments, although called the prepayment of rent, did not involve the payment of rent at all. … … What [the trust] acquired through the payments was a business with a different structure, a business in which the percentage rent payable was permanently reduced …. … The non-refundable nature of the payments suggests that they were not made to secure the right to occupy the premises under the lease and, rather, were capital in nature. ...

Leggatt LJ stated (at paras. 52-54): Counsel for Mr Jimenez … relied on a distinction … adopted … [by Rossiter CJ] in Oroville Reman & Reload … between documents of notice that merely involve the supply of information with no threat of penalties in the event of non-compliance and documents involving a compulsory process or containing a command. ... Such a measure does not involve the performance of any official act within the territory of another state – as would, for example, sending an officer of Revenue and Customs to enter the person's business premises in a foreign state and inspect business documents that are on the premises …. [T]he imposition of a civil penalty … for failure to comply with such a taxpayer notice would [not] involve an exercise of enforcement jurisdiction … provided that no steps are taken to seek to enforce the penalty in a foreign state. ...

In confirming the Tax Court’s finding that the amounts received in the reassessed years were ‘government assistance,” as defined in s. 127(9), Boivin JA stated (at paras. 3-4, TaxIntepretations translation): [T]he Tax Court … concluded that the amounts received by CAE were not made pursuant to an ordinary commercial agreement, having regard to the terms of the agreement and, in particular, the implicit rate of return, which he found to be substantially lower than the market rate for a comparable loan and therefore contrary to the commercial interests of a private lender …. … We are all of the view that the TCC judge properly applied the leading jurisprudential principles in this area as set out in … Consumers' Gas … CCLC Technologies … [and] Immunovaccine Technologies …. ...

He stated (at paras. 10-11): [T]wo of the claims raised … — those alleging procedural unfairness and a lack of an evidentiary foundation — are … best characterized as attacks on the correctness of the assessment which is the proper subject matter of an appeal to the Tax Court under the express authority of the ETA. … Iris’ third claim, that the Minister acted with an improper purpose … should … be struck here because Iris did not allege facts in its application that, if taken to be true, would give any support to this claim. ...

Before dismissing the Applicants’ applications for judicial review, Boswell J stated (at paras 55- 57): … [T]he sheer quantity of the delays did not automatically warrant interest relief. … The Delegate reasonably considered the length of the delays and recognized that certain time periods were not appropriate for interest relief and others had already been accounted for in the earlier reviews. … … [T]here were no circumstances beyond the Applicants’ control which prevented them with complying with their obligations to pay tax. ... If they paid the taxes owing as stated in the assessments, no interest would have accumulated. … … [F]or the 2014 Applicants … [u]nder subsection 220(3.1), the Minister no longer has discretion to cancel or waive interest beyond 10 years …. ... In Ludco … the Federal Court of Appeal held that evidence about other taxpayers who had benefited from an interest deduction for loans obtained in circumstances identical to those of the appellants was inadmissible…. ...

. … … [I]t would be surprising if on a proper interpretation the relevant statutory provisions gave the Minister the power to make a determination with respect to future eligibility. However, I can see nothing that would prevent the Minister from determining that the person was eligible in certain past years and informing the person that the Minister’s present intention was to assume that the person would continue to be eligible for certain future years. … Jorré DJ found that the taxpayer became eligible for the DTC in 2014, stating (at paras 21, 23, 25, 27): … I am satisfied that over time her conditions and her restrictions were getting worse. … … [T]he Appellant was doing physical labour in factories during much of the 2010 to 2014. ... …[T]he statutory tests … under subsection 118.4(1) … requires that the restriction be assessed when the individual is using available therapy and appropriate devices or medication. … [I]f an individual who would otherwise be markedly restricted is not markedly restricted through the use of medication, for example, then the individual would not meet the marked restriction test. ...

Therefore, there would have been no advantage in preparing for a tournament by studying the previous games of potential opponents. … [242] … Mr. Duhamel was playing in poker tournaments and not in private games where he could have stopped playing as soon as he lost or won a large sum of money. … [243] … Mr. Duhamel partied very often and sometimes arrived at the various tournaments in a "morning after" state. … [244] … Mr. ...