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. … There is no evidence that any GST/HST remittances were diverted to assist with the business activities. ...

. … He bills the Government of Ontario for such [medical] services in his own name. ...

., 2020 FCA 125-- summary under Subsection 152(4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4) nil assessment not subject to 3-year limitation in s. 152(4) In finding that a nil assessment was valid for s. 164(1) purposes notwithstanding that it had been issued (in 2010) more than three years after the previous (2003) reassessment, Noël CJ stated (at para. 58): Subsection 152(4) gives the Minister the power to “notify in writing any person […] that no tax is payable for the year”. ...

After March 21, 2016, the object, spirit and purpose of the Reduction Provision, as amended, was to refer to the adjusted cost basis of a policyholder’s interest in the particular policy in order to determine the amount that could be added to the capital dividend account of a corporate beneficiary, even where that beneficiary was not the policyholder. ­­­­­­­­­­­­­­­­­­­ ...

In this regard, he stated (at para. 47, citing Wild): [I]t is now established that the modification of tax attributes, such as an increase in a taxpayer’s CDA, does not give rise to a tax benefit unless and until a capital dividend is paid out of that account to a recipient capable of benefiting from its tax-free character …. ...

. … The respondent did not introduce any evidence to rebut the accountant’s account of the events. ...

The following question was posed under Rule 58: Where the Minister has at all times concluded that no partnership existed, can the Minister issue a valid Notice of Determination in respect of that purported partnership under subsection 152(1.4) …. ...

. … …The facts in Schwartz [for losses arising from the retraction of an employment offer] are too different for the decision to be meaningful to the present inquiry. ...

. … This result would be extremely difficult for the Canada Revenue Agency to audit. ...

In this regard, he noted (at para. 74) the statement in Symes that “Courts will … look for objective manifestations of purpose,” and then stated (at para. 76): [S]ubsequent actions or steps taken by Keybrand or [its parent] BWS could be used to either confirm or contradict Keybrand’s stated purpose in borrowing the funds to acquire the shares of Vidabode. ...