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In further rejecting a taxpayer submission based on no reassessment having been issued to bring the 2003 tax payable back from zero, as per the 2010 nil assessment, to the amount initially assessed, he stated (at paras. 77-78): … Markevich makes it clear that an excessive refund can be assessed even if the power to issue a reassessment for the year pursuant to subsection 152(4) has expired. ...

. … The Crown has not persuaded me that in 2008 and 2009 the purpose of the Reduction Provision was to do anything other than to reduce the addition of life insurance proceeds to a corporation’s capital dividend account by the amount of the adjusted cost basis of the life insurance policy to that corporation. ...

. … Splitting the ownership of the building and the ownership of 9118, which continued to operate the [residence], had only one goal, to minimize the taxes payable. ...

At the time the plaintiff filed his return in April 1999 for his 1998 taxation year, he did not retain a taxable benefit resulting from his conduct for which he ultimately was found to be criminally responsible …. ...

The following question was posed under Rule 58 of the Tax Court of Canada Rules (General Procedure): Where the Minister has at all times concluded that no partnership existed, can the Minister issue a valid Notice of Determination in respect of that purported partnership under subsection 152(1.4) …. ...

In summarizing this arrangement, Hogue, J.C.A. stated (at para. 42, TaxInterpretations translation): … [T]he agreed formula means that PCI must repay the advances received over 15 years if its revenues are stable. ...

The open court principle allows any person to inspect a court record and any annex "that is available to the public" …. ...

Monaghan J stated (at para. 213): … The Tax Court will address all challenges to the correctness of the assessment made after the transfer pricing provisions have been applied, including whether the conditions for their application are met, the amount of any adjustments, the liability for penalties and whether the Minister exercised her discretion properly. ...

Harris filing returns showing employment and dividend income from 405 Canada – and although those returns were filed after 405 Canada’s VDP application, “[i[t would be incongruous” for the 405 Canada disclosure to be rendered voluntary “simply because a related taxpayer did not file the returns that would reveal the same information until after filing a VDP application” (para. 19). the possibility mentioned by CRA in its enforcement letter of arbitrarily assessing Mr. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...