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(The taxpayer testified that he spent $104,719 to install a gravel road for ¾ of the property length in order to free up a pick-up truck that had become stuck in peat.) ...

Hershfield J referred (at para. 91) to this being from the perspective of Mall Co a " quid pro quo from ICBC to forego its entitlement against Tech BC. ...

. … CIBC’s answer to question 5591 merely states that…legal advice informed its position. ...

. … [T]he fact that Chapter 2 was introduced partly for the purpose of forestalling tax avoidance schemes self-evidently makes it difficult to attribute to Parliament an intention that it should apply to schemes which were carefully crafted to fall within its scope, purely for the purpose of tax avoidance. ...

Ss. 26(1) and (2) provided that the amount of allowable input tax is that which is “attributable to” taxable “supplies … made or to be made by the taxable person in the course or furtherance of his business.” ...

Wagner and Gason JJ. stated (at paras 17, 19 & 20): Solicitor-client privilege has evolved from being treated as a mere evidentiary rule to being considered a rule of substance and, now, a principle of fundamental justice… …[F]acts connected with that relationship (such as the bills of account at issue in Maranda [2003 SCC 67, [2003] 3 S.C.R. 193 at paras. 33-34]) must be presumed to be privileged absent evidence to the contrary…. ...

. … Hélie Holdco served only to participate in the transaction for the benefit of Mr. ...

Similarly, respecting the divestiture-related fees of Lazard Frères incurred up to board approval of a butterfly spin-off, these related to advice and approaches to potential third-party purchasers of the shares through which the laminated products business was held as well as to the ultimate sale (on a rollover basis) of the shares of that laminated products company to Novelis in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis, and the calculation of the Lazard Frères success fee did not represent a percentage of the value of those shares – so that those fees also were deductible under s. 20(1)(bb) as well as under s. 9. ...

It is the place that Courts of Appeals have called the corporation's 'nerve center' … and not simply an office where the corporation holds its board meetings….” ...

. … I am inclined to favour a narrow construction of double taxation such that it arises where the same amount is taxed in the hands of the same person. ...