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C.R. 1, should accordingly read: … if there is an expenditure which would be made in any case, from which [income] may accrue, the expenditure may be deducted; but an expenditure which will not be incurred unless there is [income] is not an expenditure in order to earn [income]. ...

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. ...

Of the factors listed in Rule 147(3), those arguing for increased costs were: the costs at issue ($2.2 million for the taxation year at issue, similar amounts for two other taxation years, and $10 million in a number of related appeals); the complexity of the issue (including taking into account reported proceedings in Deans Knight, requiring the parties to “regularly … rework their arguments” (para. 14); and the taxpayer’s failure to concede until oral argument that there was an avoidance purpose for the creation of Class C non-voting shares. ...

Nonetheless, the Crown did not agree to be bound by those findings until the eve of trial – and this delay in following BC Ferries caused the Appellant to incur substantial costs. ...

(para. 48) “[T]he transactions were structured in the way they were to benefit Corco … [which] needed a way to finance the purchase.” ...

An RVO advances the same goals as an AVO — albeit by employing a different transaction structure. ...

By committing itself to issuing 1,380,000 shares to a trust for the benefit of all eligible employees, the Company failed to meet the requirements of subsections 7(1) and 7(2) …. ...

By committing itself to issuing 1,380,000 shares to a trust for the benefit of all eligible employees, the Company failed to meet the requirements of subsections 7(1) and 7(2) …. ...

. … [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. ...

In finding that s. 160 applied to the transactions in light inter alia of the cash proceeds received by Harvard Properties exceeding the FMV of the Newco shares sold by it, Boyle J found (at para. 166) that Harvard Properties had failed to establish any value for the shares, stating (at para. 174): There appears to be little to no chance that any arm’s length party unrelated to these transactions would agree to accept, much less pay for, the HP Newco shares at the relevant time as the Newcos would moments in time later have no assets, no business, and the possibility of a significant liability for their roles in these transactions …. ...