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. … [and] that directors and/or shareholders may make a decision and act upon it, even though they may not record that decision in writing until a later date. ...

. … The focus of [s. 20(1)(c)] is the current use of the borrowed money, not on the current ownership status of the property initially acquired with it. ...

As subsection 123(1) makes clear, this exceptional treatment is restricted to non-resident insurers …. ...

Before so finding, he stated (at para. 29): … I am not convinced that section 53 of the Rules, respecting the striking of pleadings, is the equivalent of a rule permitting the Court to render a summary judgment. ...

Before concluding that the ARQ had not exceeded its territorial competence in making this requirement, Rowe J found that the sending of the requirement to the Calgary branch (which was deemed to be a separate entity only for the limited purposes of s. 462)) did not detract from the fact that it was sent to a person (the bank) that operated in Quebec, stating (at para. 88): It would be absurd if the procedural requirements imposed by s. 462(2) … were understood to affect the ARQ’s authority to issue a formal demand to a bank that operates within its territorial jurisdiction. ...

… I cannot imagine why in a case such as this the CRA would prefer to have Mr. ...

Sommerfeldt J stated (at para. 49): … [A]s 137ON was still endeavouring to obtain the requisite approvals to construct a storage container facility on the Subject Property, it had not yet begun to use the Subject Property in the course of its commercial activities. ...

Accordingly … each of the Invoices, by specifying the amount of the fee to be paid, with the implied requirement that the fee be paid in cash within a reasonable time, has satisfied the requirement in subparagraph 3(c)(iii) to set out the terms of payment. ...

The spin-off mechanics were conventional, and at their conclusion, there were two promissory notes for $30M owing by Oldco and Newco to each other – which then were set-off. ...

The Queen, 2019 TCC 156-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract debt is obligation to pay a sum certain or amount reducible to sum certain After quoting (at para.55) the statement in Sattva that “While the surrounding circumstances are relied upon in the interpretive process, courts cannot use them to deviate from the text such that the court effectively creates a new agreement,” Owen J found that, contrary to the taxpayer’s understanding of the arrangements as reflected in its financial statements, the arrangements at issue had not in fact been structured so as to give rise to a debt owing to the taxpayer by a corporation that subsequently became bankrupt – so that the taxpayer’s claim for a business investment loss was properly denied. ...