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They 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 FLL and most likely the term of any renewal of the FLL. ... As a matter of substance the payments, although called the prepayment of rent, did not involve the payment of rent at all. … What MFT acquired through the payments was a business with a different structure, a business in which the percentage rent payable was permanently reduced from what it otherwise would have been. … … 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. ...

Before determining to award pre-offer costs of 35% of BMO’s actual costs of $684,471, Graham J stated (at paras 4, 6 and 7 and 8): The general wording of subsection 147(3.1) … indicates that a party receiving substantial indemnity costs following a settlement offer is entitled to party and party costs to the date of service of the settlement offer. … … Awarding substantial indemnity costs provides an incentive to settle early…. Subsection 147(3.3) ensures that offers are made early by requiring that … an offer must be made at least 90 days before the hearing and must not expire earlier than 30 days before the hearing. ...

Agence du revenu du Québec, 2021 QCCQ 4841-- summary under Subparagraph 6(6)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(6)- Paragraph 6(6)(a)- Subparagraph 6(6)(a)(i) a Montreal site qualified as a special work site for a 3 ½ year project The taxpayer, who had purchased a house in Richmond, Quebec in 1999 to reside there with his family, worked for his employer (“GPH”) as a project engineer regarding the construction or expansion of factories. Although normally, on such projects, the client of GPH would pay the accommodation costs of the GPH employees who worked on the project, that was not the case for a project for one of the clients in Varennes (outside Montreal, and 90 minutes away from Richmond), which started in 2014 and lasted for 3 ½ years. ... In finding that these amounts were not includible in the taxpayer’s income pursuant to the Quebec equivalents of ITA ss. 6(6)(a)(i) and (b)(i), Lapierre JCQ stated (at paras. 47, 49): [T]he fact that the wife and one of the children of the couple also lived in the Longueuil apartment is not very important in this specific case. … … Mr. ...

IX, s. 2(d) on the basis that this provision referenced the ordinary location of the insured vehicles, and there was no evidence on that point – and accordingly confirmed the denial of Northbridge’s related input tax credit claims. ... An accident (or other insurable event) occurs at a particular location. … … Since the policies issued by Northbridge in part related to accidents (and other insurable events) that are usually situated outside Canada, the supply of a portion of the policies qualified as a zero-rated supply. … “[R]isks” means the risk of a claim arising from an accident or other insurable event. ...

In July 2013, the husband transferred his ½ co-ownership interest (the “Interest”), in a real estate property that they co-owned, to her for no stated consideration. ... In the course of finding (at para. 42) that half of the Transfers constituted loans made by the taxpayer to her husband and the Company and (at para. 58) that the transfer of the Interest to her was in repayment of part of such loans, Lafleur J stated (at paras 52): … [W]hile … toward the banks, each of Mr. and Mrs. ... Nelson, as “a co-debtor, while liable to the creditor for the full amount, is only liable as among the co-debtors for his or her share” (Lafrentz v M & L Leasing, 2000 ABQB 714 … at para 32 …. ...

This general principle was identified … in … Simard-Beaudry … as …: …[T]he taxpayer’s liability results from the Act and not from the assessment. ...

All individuals, corporations, trusts or partnerships are required to complete and file form T1135 …. ... In rejecting most of the respondents’ submissions, Boswell J stated (at paras. 23, 25 and 27): [A]ny valid reason, such as a suspicion of offshore holdings, meets the low threshold for the reasonableness of an audit …. … There is no statutory time limit within which to make a request for information under subsection 231.1(1) …. ... Because it is not at all clear whether the Letter was directed to the Respondents individually or their connected entities, the first requirement of section 231.7 … for obtaining a compliance order has not been satisfied by the Minister …. ...

There is, in fact, no specific finding … that … any fixed place of business has been put at the disposal of these companies. … The High Court … held:...It is clear … that the Indian company only renders support services which enable the assessees in turn to render services to their clients abroad. Nariman J further found that there was no services PE under Article 5(2)(l), stating (at paras 17, 18, 20): Insofar as a service PE is concerned, the requirement of Article 5(2)(l) of the DTAA is that an enterprise must furnish services “within India” through employees or other personnel. … It has already been seen that none of the customers of the assessees are located in India or have received any services in India. This being the case, it is clear that the very first ingredient contained in Article 5(2)(l) is not satisfied. … If any customer is rendered a service in India, whether resident in India or outside India, a “service PE” would be established in India.... ...

In going on to find that the Report was not protected by disclosure on the basis of the BP case, Southcott J found (at paras 65 and 66): … I agree with the Minister’s position that BP is to be read as precluding general and unrestricted access to TAWPs [tax accrual working papers] on a prospective basis, outside the context of an audit of particular issues. … … Unlike in BP, the Minister’s request for access to the Report in the present case is made in the context of an active audit of particular issues. ...

. … … Mr. White did not defeat or in any way hinder the Minister’s efforts to collect any tax he owed by placing his remuneration in the Joint Bank Account. The Minister could have taken collection action with respect to funds in the Joint Bank Account. … Once the funds were placed in the Joint Bank Account, the Appellant had the ability to effect a transfer; however, such transfer did not occur until the Appellant removed the funds from the account. ...