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In rejecting the appellants' arguments that the Part III assessments were statute-barred, Smith J stated (at paras. 93-94): … The Appellants cannot argue that the nil reassessments are statute-barred and then ask the Court to extrapolate from that and conclude that the Part III Reassessments that are the subject matter of these appeals are also statute-barred and “therefore invalid and without legal force.” ... Moreover, … nothing prevents the Court … from reviewing the validity of transactions that are alleged to have triggered the subject capital gains and capital losses and that are alleged to form the basis for the additions made to the capital dividend accounts. Before going on to find that the purported acquisition by the appellants of trust units that had a high tax basis (whose alleged disposition generated the capital losses) were a sham, he stated (at para. 95): If I am wrong in so concluding, then I find that the Part I Reassessments were not statute-barred and that the Minister was entitled to issue them because … the Appellants had made a misrepresentation that was attributable to neglect, carelessness or wilful default or fraud, as required by subparagraph 152(4)(a)(i) of the ITA. ...

Before rejecting these submissions, Mactavish JA noted (at para 40): … The Minister’s discretion must … be genuinely exercised, and must not be fettered or dictated by policy statements such as Income Tax Information Circular IC 07-1R1: Stemijon Investments Ltd. v. ... [and] noted that the [CRA] intercept letters gave the appellants the option of having their tax returns assessed without the … deductions. ... He considered the appellants’ submissions and explained why he was not persuaded that any additional relief was warranted …. ...

" See summary under s. 9 – capital gain v. profit – real estate. ...

[in] Palmer … [1980] 1 S.C.R. 759 …. The evidence could not have been adduced at trial, it is relevant in that it bears on a decisive or potentially decisive issue on appeal, is credible, and could reasonably be expected to have affected the result in the Federal Court. ...

. … [T]he VAT Directive … must be interpreted as precluding national legislation, such as that at issue in the main proceedings …. ...

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. ... Giguère testified to for the purpose of unsecured financing of vehicle inventories …. ...

Here, that is visa status, a characteristic which depends on nationality – a person not being an Australian national – the very attribute protected by Art 25(1). … Discrimination jurisprudence establishes that the circumstances of the person alleged to have suffered discriminatory treatment and which are related to the prohibited ground are to be excluded from the circumstances of the comparator. ...

The Queen, 2018 TCC 262-- summary under Subsection 165(1) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(1) objection can be made after the proposal letter and before the notice of reassessment – but must state “I object” On May 11, 2015, the taxpayer was sent a letter by Mr. ... Payne did not qualify as a notice of objection, and that the taxpayer was out of time for an extension under s. 166.2(5)(a), Sommerfeldt J stated (at paras 17, 18): …[T]o be a notice of objection, a document “must include an actual objection to an assessment,” or at least some indication that the particular taxpayer is objecting to an assessment. … [The taxpayer's] letter of April 27, 2015 … does not contain any statement taking issue with the CRA’s categorization of those expenses. … Unfortunately, I have been unable to find anything in the letter to indicate that [the taxpayer]... was objecting to a reassessment. ...

Tool & Die Company Limited to W.S.W. Tool & Die Inc., the writ of execution and report of nulla bona were in the former company name. ...

. … The idea that … a company, has a separate legal personality from its shareholders has been protected and reaffirmed from Salomon v A Salomon & Co Ltd [1897] AC 22 onwards. ...