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In finding that there also was no reversible error here, and that it was reasonable to allocate a portion of the purchase price to the goodwill, Morissette, JCA stated (at para. 40): The SR acquired by SECA offered … services … that … varied by unit and by resident choice. ...

In granting the order and rejecting the taxpayer’s submission that the request letters were issued in connection with “a criminal investigation going on behind the scenes of which the [CRA] Auditor ha[d] no knowledge,” Russell J stated (at paras 50, 55, 58 and 59): … Offshore accounts are not, per se, illegal and it is the duty of the Minister under the Act to inquire and ensure that those with offshore accounts are meeting their tax liabilities. … If the Respondent’s position were accepted, it would mean that, given the government’s intent to deal with offshore tax offenders, every Canadian taxpayer with an offshore bank account would be immune from compliance with the audit requests made under s 231.1(1) because this could lead to criminal proceedings at some time in the future. ... See Jarvis …. It is … clear that, even if a CRA auditor has a suspicion that an offence may have occurred, a mere suspicion does not change the predominant purpose of an audit into a criminal investigation. See Jarvis… … Given that the Auditor’s evidence is that the Respondent “has not reported [the] existence of any money, securities, or assets in HSBC Swiss account(s), nor any income earned therefrom,” it is certainly possible that CRA could have begun an investigation to establish the elements of criminal tax evasion, although there is no evidence that it has. … Assessing the totality of the circumstances … I conclude that the predominant purpose of the request letters is a civil tax compliance audit and that no adversarial relationship between the state and the Respondent exists. … Ellingson … made it clear that the Jarvis test must be based upon evidence, and cannot be based upon the subjective suspicions of the taxpayer involved. … ...

. … Whilst it may be true that only foreign nationals can obtain and hold a “working holiday visa” there is no requirement to hold one because of their nationality. … [I]t was not suggested that Ms Addy was not entitled to apply for any of the other range of visas which may have been available. ... The foregoing suggests that the Rates Act does not discriminate on the basis of nationality. … …[T]he O.E.C.D. ... III of Sch. 7 of the Rates Act, but rather her derivation of working holiday taxable income. … … Critically, both Australia and the United Kingdom are free to discriminate on the basis of tax residency. … ...

. … … [S]ection 16 of Part III refers to instructing individuals in courses “other than courses in sports, games, hobbies or other recreational pursuits that are designed to be taken primarily for recreational purposes ”. ... Regarding the exemption in s. 3, she stated (at para. 47): If the school day hockey program offered by Victus Academy to its academic students is a separate supply …it is a supply of services (on-ice training and off-ice conditioning) made by Victus Academy, a school authority, primarily to its (academic) elementary or secondary students during the course of extra-curricular activities …. ...

The appellant declined the offer …. … I am not satisfied that the CRA acted in bad faith, misled the Appellant, trapped or abused procedures that were unjustified in the circumstances. … The concept of estoppel is a common law concept that has no equivalent in Quebec civil law. ...

In fact, the Appellants just seemed to ignore it, when in my opinion, having regard to their skills in and knowledge of the securities industry from working as executives for a wealth management firm and the multiple other circumstances or red flags that went up … they were clearly aware of the impact of the IPO’s value on their holdings. In affirming these findings that the CRA assessments were not statute-barred, Boivin JA stated (at para. 5): We are all of the view that the Judge correctly identified and applied the two-step approach to determine whether the appellants could be reassessed beyond the normal reassessment period pursuant to subparagraph 152(4)(a)(i) of the Act (Vine …). … We all agree with his conclusions for essentially the same reasons. ...

Furthermore, respecting the Crown’s argument that s. 150(2), which expressly provided that s. 150(1) did not apply to imported supplies, implied an intention the s. 150(1) would apply to the exported services of WMI, Noël C.J. stated (at para. 50): [S]ervices in contrast with tangible goods cross the border only in a virtual sense so that the exigible tax on imported services cannot be collected in the usual way – i.e., at the time of entry when the goods are released …. ... As explained in the commentaries which accompanied the amendment to subsection 150(2), “[a]pplying the closely-related group election to those supplies would result in both parties to the election avoiding tax altogether …” …. ...

Furthermore, … without having made an oppression claim, Mr. Abenaim would never have received an amount of [confidential]. … … Schwartz indicates that, where it is established that a payment has a dual aspect, the bar for determining its allocation is not that high. … In this case, I am of the view that the best approach in determining the breakdown of the amount received by Mr. Abenaim is to refer to the civil action. … The [confidential] amount is well in excess of the amounts accorded by the courts in Quebec…. ... Abenaim. … According to the judicial guidelines, compensation in lieu of notice in this case would be $390,000. ...

. … [T]he IRPA temporary resident regime explicitly requires the conferral of temporary residency by an immigration officer. … … From June 27, 2011 to February 21, 2013, she was a refugee claimant. … From February 22, 2013 (when her refugee claim was denied) to September 15, 2015 (when permanent residency was granted to her), the appellant had no status in Canada. ...

. … … 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. ...