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After having noted that the word “document” (used in s. 288(1)) was defined in s. 123(1) to include “a record” which, in turn, was defined to include “any other thing containing information, whether in writing or in any other form ” (her emphasis), she also rejected (at para. 22) the contention of Tellza that “the request for records in an electronically readable format, along with the system administrator’s user ID and password, where applicable, falls outside the scope of the inspection power in the ETA s 288(1).” ...

Before concluding that 9267 was not entitled to the s. 231(1) credit, D’Auray J stated (at para. 42, TaxInterpretations translation): … 9267 did not remit GST on the taxable supply, i.e., on the sale of its domain names to 9210, when it filed its return. ...

. … Parliament does not want to grant a tax credit where the donor is not impoverished and the charity is not enriched. ...

In the case of a lease, there can be no assignment of the lease to the limited partnership – it must be assigned to the general partner. ...

In finding that, in those post-wind-up year, GMI was continuing to carry on the GNC business, Archambault J stated: … GNC’s primary purpose was to sell natural gas, and incidentally to supply services of converting vehicles to natural gas. ...

In finding that it was an EBP, he cited (at para. 29) Oldman for the proposition that “[o]rdinarily … an Act of Parliament must prevail over inconsistent or conflicting subordinate legislation,” and then stated (at para. 30): [S]ince the definition of a prescribed trust is set out in the Regulations, the paramountcy of the definition of an employee benefit plan in the Act must govern. ...

Furthermore, the secretary of her husband’s accountant prepared a “Form 1 – Initial Return/Notice of Change” stating that the taxpayer’s directorship started on September 4, 2003 and ceased on December 12, 2003, although the accountant’s recollection of it having been sent to the Ontario Ministry of Consumer and Commercial Relations, was not reflected in the Ministry’s records. ...

However, Southcott J accepted the taxpayers’ submissions in this regard by concluding (at para. 111) that “s 231.1 … does not authorize issuance of a demand compelling the recipient to provide, through written answers to questions, substantive information relevant to a taxpayer’s tax position” as contrasted to “authoriz[ing] compulsion of only pre-existing documentation” (para. 79). ...

., Branigan, 2004 FC 245)] …. Southcott J found however that the somewhat detailed affidavit evidence of a CRA manager was sufficient to meet the burden on the Minister to establish service of the s. 231.2(1) requirements, even though the requirements of s. 244(5) had not been met. ...

. … It is therefore necessary to consider, on a document-by-document basis, whether each Sample Document is subject to legal professional privilege. ...