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. … Nothing in this case justifies a different decision [than in BBM]. ...

In finding that the appellant had continued to be a “registrant,” so that ss. 171(3) and 200(2) did not apply, Favreau J referenced s. 141.1(3) and stated (at paras 57- 60, TaxInterpretations translation): The sale of equipment following the cessation of normal daily activities is … part of what the ETA terms "commercial activity". ...

. … Advisory CIP significantly expands the quantity of relevant evidence that is denied to the courts. ...

. … Words and Phrases credit note ...

However 15 months later, CRA vacated the s. 55(2) assessment of 8231 for reasons that are not explained – so that the only outstanding s. 55(2) assessments were of the corporations (807 and 810) acquired by the purchasers. ...

. … If by issuing no definition, the result was, as the Appeal Division held, that the claim of exemption failed it would mean that by the simple expedient of not making use of the defining power, the Minister could make his decisions unassailable. ...

After finding (at para. 45) that “subsection 3(h) is ultra vires in so far as it applies to alcoholic beverages,” and in concluding that the respondent was entitled to a rebate based on the 19% rate if tax actually imposed rather than the 8.1% rate in s. 3(h), Noël J.A. stated (at para. 68): The purpose of the Act in this case is … clear. ...

In addition, Interoil provided the shareholders with considerable information on the value of the new Arrangement and the value of the contingent resources; b) the Transaction Committee was independent, examined and endorsed the arrangement; c) the Fairness Opinion was independent and addressed the deficiencies of the previous fairness opinion; d) the shareholders had access to dissent and appraisal remedies and those who indicated they wished dissent rights were reduced from 10% on the first plan of arrangement to 1 % on the new plan of arrangement. ...

. … The use of the word “habituelle” in French…makes it even more clear and certain that the use of the word “primary” to qualify “place of residence” in English is not to suggest that the new housing rebate is only available to those who also have at least a second home also used as a place of residence. ...

CRA asserted that the competent authority proceedings did not result in binding agreements between Sifto Canada and CRA and, even if they did, they did not fix the arm’s length transfer price – so that CRA was not only authorized, but was required, by the ITA to issue the post-audit reassessments once in possession of the new audit information. ...