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He stated that "the expectation of privacy with respect to business records … is very low" and that "the information sought … is required in the context of verification activities undertaken … to determine whether the Unnamed Persons have filed their required tax returns. ...

As such, a policy that is relied on by decision-makers in the day-to-day administration of their governing legislation, cannot supersede the authority provided under the legislation …. ... In rejecting a further argument of the applicants (at para. 118) that “there was a legitimate expectation that CRA would follow their own policies and procedures as set out in the 2015 Manual,” Elliott J first stated (at para. 120): A legitimate expectation arises when a government official makes “clear, unambiguous and unqualified” representations within the scope of their authority to an individual about an administrative process that the government will follow: … Mavi, 2011 SCC 30 …. ... The Court may only grant appropriate procedural remedies to respond to a legitimate expectation …. ...

When a substantial deficiency in shareholders’ equity subsequently emerged, a negotiated Settlement Agreement concluded more than a year after the sale reduced the sale price by $0.5 million (to $15.5 million), increased the portion of the sale price payable under the reverse earn-out to $3 million – and provided that the vendors would reimburse a further portion of the sale price out of amounts received by them under the earn-out. ... See summary under s. 54 – proceeds of disposition – para. (a). ...

When a substantial deficiency in shareholders’ equity subsequently emerged, a negotiated Settlement Agreement concluded more than a year after the sale reduced the sale price by $0.5 million (to $15.5 million), increased the portion of the sale price payable under the reverse earn-out to $3 million – and provided that the vendors would reimburse a further portion of the sale price out of amounts received by them under the earn-out. ... See summary under s. 54 – proceeds of disposition – para. (a). ...

The Queen, 2018 TCC 144-- summary under Person Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Person person includes an heir of the person irrespective of also being a legal representative The definition of a “person” indicates that such word “includes … the heirs, executors … or other legal representatives of such a person.” ... She rejected the Crown’s argument that, in order to have this ability, the heir was required by the quoted wording to have been an heir who was also a legal representative, stating (at paras. 38, 44): [T]he word “heir” found in the definition of “person”, the meaning of which is determined in accordance with the applicable private law, does not necessarily have the same meaning as the word “heir” found in the definition of “legal representative of a taxpayer” as defined under subsection 248(1): in order for an “heir” to be a “legal representative of a taxpayer” under that latter definition, the heir must administer, wind-up, control or deal in a representative or fiduciary capacity with the property of the Estate. … Parliament cannot have intended that an assessment be immune to a judicial challenge. ...

. … The Minister must still consider … the three criteria he is mandated to consider in subsection 207.06(2) … to discharge his discretionary duty. ...

Before reversing the decision below to confirm these reassessments, the Court of Appeal stated (at para. 13, TaxInterpretations translation): The appellant was not required to make out a prima facie case that the 7.89% rate was unreasonable but, rather, that the assumption, on which the respondent relied in assessing it, that the 10% interest rate deducted from its income for the taxation years in issue was not "reasonable in the circumstances," … was prima facie … unsound. Since the 10% rate actually used fell within what the above evidence indicated was a reasonable range, such a prima facie case had been established – so that the onus shifted to the ARQ, which had “failed to demonstrate by a preponderance of the evidence that the 10% interest rate was unreasonable within the meaning of TA section 420.” ...

Canada, 2020 FCA 90-- summary under Redundancy/reading in words Summary Under Tax Topics- Statutory Interpretation- Redundancy/reading in words narrower construction avoided rendering language redundant Before going on to indicate that the expansive interpretation of s. 149(1)(d.5) submitted by the taxpayer would have the effect of making it unnecessary in the provision to refer to a municipality, Mactavish JA stated (at para, 52): [L]egislatures generally avoid the use of unnecessary or superfluous words in legislation, and that every word in a statute is presumed to have a specific role to play in advancing the legislative purpose: … Proulx, 2000 SCC 5 ….. ...

. … Before 2007 … it would appear that the risk borne by Visa Canada was almost entirely non-existent, with the risk instead largely being borne by Visa International and the issuing financial institutions. ... …Proposed subsection 4(1) of the Regulations stipulates that a "person at risk" does not include a person who becomes at risk solely through the provision of a clearing, settlement or authorization service. … [O]therwise taxable administrative services, such as those provided in respect of credit card transactions, do not fall within the definition of a "financial service" only because the service provider agrees to assume the remote risk of honouring the payment authorized under the credit transaction in the event of a failure by the relevant financial institution. ...

. … Justice Sharlow … [in Arnaud] concluded that paragraph 146(9)(b) did not apply to the case before her since there was no collateral arrangement. … [T]he appellants here did not enter into any collateral agreement that would have allowed them to recover their loss in whole or in part. ...