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The shareholder group consisted of (i) two unrelated individuals (Souty, and Foix – who held his shares through a passive portfolio company (“Virtuose”),) (ii) trusts for the two respective families (the Souty and Foix Trusts) and (iii) after giving effect to intricate preliminary transactions, two holding companies for Souty and Foix through which they held a portion of their shares of W4N (in the case of “Souty Holdco”) or of Virtuose (in the case of “Foix Holdco”). ... He went on to indicate (at para. 67) that “the scope of subsection 84(2) is sufficiently broad to counter this type of distribution when the property being distributed is fungible and a third-party facilitator is involved in the extraction process” and (at para. 69) that “it would be contrary to Parliament’s intention to turn a blind eye to the existence of a distribution or appropriation for the sole reason that, for example, the shareholder received the target corporation’s property as a creditor rather than as a shareholder … or, as in the present case, that the funds received by the shareholder originate directly from a third party but indirectly from the target corporation.” ...

. … Here we have a sale of mortgages of which the servicing is not only an integral part but is requisite as a matter of commercial exigency. ...

. … [A] few services to a few customers does not change the inherent nature of income from property. ...

Trudel JA found no reviewable error in the finding of Boyle JA that as "Dividend B was paid in proportion to shareholdings then it could not have been paid ‘in proportion to assessments ' and thus Dividend B would clearly not fall within the ambit of paragraph 137.1(10)(a)" (para. 49). ...

The USA required unanimous approval by the board (with at least one of SGF's directors included) or of the shareholders for a wide range of matters – including of the capital and operating budgets and changes thereto, business plans or departures therefrom, the hiring or dismissal of various officers or payment of bonuses, any significant financing or security interest grant, and any entering into or changes in various significant contracts. ...

S. 56(2) did not apply to redistribute $8,000 (= $10,000 x 400/500) of the $10,000 dividend received by Mrs. ...

It was also irrelevant that the taxpayer did not object to the 2009 reassessment, because " Canadian Marconi is strong authority that an out-of-time reassessment is void absent an allegation of fraud or misrepresentation" (para. 62). ...

Lehigh Cement Limited, 2014 DTC 5058 [at at 6849], 2014 FCA 103, aff'g 2013 DTC 1139 [at 740], 2013 TCC 176-- summary under Paragraph 95(6)(b) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(6)- Paragraph 95(6)(b) restricted to status-manipulating acquisitions or dispositions The taxpayer ("CBR Canada") directly (as to 99%) and indirectly (through a wholly-owned Alberta subsidiary as to 1%) used $US 100 million borrowed from two arm's length non-resident banks (with the principal but not the interest obligation under the first loan then being assigned by the first bank to a Belgian subsidiary of the taxpayer's ultimate Belgian parent – "CBR SA") by making capital contributions to a US LLC, which used those funds to make interest-bearing loans to a U.S. sister corporation ("CBR US") of CBR Canada. ...

. … …[T]he letter…was an amendment to the estate's tax return and its effect was to amend the initial return. ...

. … Once the general operation of the GST Act is understood in that way, it is apparent that there is no warrant in the text or policy of the GST Act for reading the reference in the special rule in s 40-35 to a supply of "residential premises" that is a supply "by way of lease" as referring to the supply which occurs at the time of entering into the lease but not as referring to the further supply which occurs by means of the lessor observing and continuing to observe the express or implied covenant of quiet enjoyment under the lease. ...