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., 2024 TCC 12-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) acquisition of loss company and its merger with a loss user 1 ½ years later were part of the same series In September, 2007, most of the equity of an insolvent public corporation (“Biomerge”) in CCAA proceedings was acquired by the company (“Nexia”) of two individuals involved in acquiring and selling loss companies, resulting in Nexia holding all of non-voting common shares of Biomerge (representing 80% of its equity) and 45% of its voting common shares (the “CCAA transactions”). ...

Regarding s. 7, Bocock J noted the finding in Carter (2015 SCC 5, at para. 64) that security of the person is engaged by “state interference with an individual’s physical or psychological integrity, including any state action that causes physical or serious psychological suffering” and found (at para. 136) that “[w]hile the mental health of the Appellants and their children was impacted, this does not constitute a ‘serious and profound effect’ ….” and, as to the issue of causation (para. 142): Any physical or psychological hardships experienced by the Appellants were initially caused by their difficult financial or domestic situations subsisting before applying for the CCB, which were not caused, perpetuated or worsened by the Canadian state before or after entry. ...

The “eligibility requirements … do not deny the benefit in a way that perpetuates, reinforces, or exacerbates disadvantage” (para. 223). ...

The jurisprudence clearly demonstrates that ignorance of the provisions of the ITA and of the obligations of taxpayers in managing their TFSA accounts, or the receipt of bad advice, do not constitute a "reasonable error" within the meaning of subsection 207.06(1), justifying the exercise of the Minister's discretion …. ...

St-Hilaire J found (at para. 60) that the relevant part of the Reply “may prejudice the fair hearing of the appeal and is an abuse of process” and should be struck – but with leave to the Crown to amend its pleadings. ...

The board of GEFI Inc [a subsidiary of GEFI], as the LP's general partner, did not make strategic decisions and in fact had "very little involvement" …. ...

. … [T]he fair market value of a business as a going concern plays no role in determining the proceeds of disposition, or consequential recapture, of depreciable property under the Act. ...

. … [P]roviding advice to a lawyer as part of an overall retainer, even if the lawyer then incorporates it into their own legal advice, does not make a communication privileged. ...

However, he considered, given that there was no base erosion going on where the cross-border services were fully reciprocal (as here), that s. 95(2)(b)(i) should be interpreted as applying “solely to situations where a net positive amount is paid from Canada to the foreign affiliate” (para. 76) – so that s. 95(2)(b)(i) did not apply here given the greater value of the southbound services of BlackBerry. ...

. … Consistent with the statutory scheme, the Minister reserved the right to conduct an audit of the claimed ITCs to determine whether they related to an exempt or zero-rated supply, and to reassess accordingly. ...