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(para. 4) It was also immaterial that s. 256(7)(c)(i) (dealing specifically with a transaction of this type) was added only subsequently (“ Deans Knight … did not look at other provisions enacted after s. 111(5) in order to determine the object, spirit, and purpose of s. 111(5).” ...

One line reflects a purely textual approach, not affected by any retroactive change of circumstances applying to the pertinent taxation year. … The other line of authority … recognizes as relevant a subsequent order cancelling support arrears arising in the context of a de facto shift of a child’s primary residence…. In Barthels, … Hershfield TCJ considered that subsequent cancellation of support arrears where a custodial child had moved to the claimant parent’s residence did neutralize the original requirement to pay support amounts. … Russell J further stated (at para 19) My preference as to these two lines of authority is that represented by Barthels. ... … In this regard, he held (at para 26): … I concur with the decision of this Court in Young, … per Sarchuk, J., that no statutory language used in or in connection with subsection 118(1) indicates that the deductions may be prorated for a taxation year, noting in contrast with other provisions in the Act by which Parliament has explicitly provided for proration. ...

To conclude otherwise would improperly and adversely impact the interests of the third-party beneficiaries of the VSI Trust. … The common law recognizes a distinction between legal and beneficial ownership. A person having beneficial ownership in property can enforce their beneficial ownership rights against the holder of legal title. … Justice Brown … observed that a trustee holds trust property solely for the beneficiaries’ enjoyment and cannot profit personally from their dealings with the trust property or with the beneficiaries of the trust (Valard [2018 SCC 8] at para 17). Justice Côté echoed these principles … in Canada North Group stating “[p]roperty held in trust cannot be said to belong to the trustee because ‘in equity, it belongs to another person’ (Henfrey [[1989] 2 S.C.R. 24], at p. 31)”. ...

., the plaintiffs had transferred the property …. It was the deed of sale, in the clause entitled “Price,” that “entitl[ed] … to proceeds of disposition of the property, ” to repeat the words used in TA section 248. … It was otherwise and as bare owner, which necessarily involves the transfer of property and its disposition, that 9212-7133 Québec Inc. granted to the plaintiffs a dismemberment of the right of property, in the form of a right of usufruct. ...

See summaries under Financial Services and Financial Institutions (GST/HST) Regulations, s. 4(2) and s. 123(1) – financial service – (f.1) and (r.4). ...

The tax policy underlying paragraphs 110(1)(d) … and 6204(2)(b) … is to prevent the turning of stock option plans into forms of additional remuneration and to ensure that the employees subscribing for these shares are exposed to a certain level of risk. ...

Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into income The taxpayer was an Australian resident who was taxed at the 15% long-term U.S. capital gains rate on his gains on disposal of U.S. oil and gas drilling rights. ...

The Appellant may wish to consider making an application for a reduction of the penalty and interest under … subsection 220(3.1) …. ...

. … [The taxpayer] … would know whether he had the necessary donative intent in order for the payment of $65,000 to CLES to qualify as a charitable donation. ...

There is also a further 50% refundable tax on the RCA’s income from business or property for each year as well as its capital gains for the year [citing s. 207.5(1) – refundable tax – (b)]. ...