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He further stated (at para. 75): [I]n Ver, Justice Bowman indicated that the question of whether an expenditure was made for a business or a personal purpose is a matter of judgment, and not the subject of a misrepresentation within the meaning of subparagraph 152(4)(a)(i) …. I adopt that view, except to the extent that either of the Appellants has acknowledged, or it is patently obvious, that a particular expenditure was incurred for a personal purpose, or was not incurred for a business purpose …. ... Accordingly, the reassessments were statute-barred except to the extent that they “were clearly personal, as distinct from those whose determination may have been ‘matters of judgment’ of the type discussed … in Ver ” (para. 105). ...

No judicial orders were mentioned in the Reply – apart from the … divorce order. ... In view of that, and the Respondent's deficient pleadings, and the Appellant's own testimony and documentation as at least slight evidence tending to support that during at least certain relevant periods he was the parent with primary responsibility for care and upbringing…, I find …the Appellant … was the person primarily responsible for the care and upbringing of JCW throughout the period of January 2013 to and including March 2015. … ...

In finding that the oil-processing equipment included in TMT 4 and 5 also so qualified, he stated (at paras. 82-83): … [T]he oil processing equipment in TMT 4 was also constructed to be used by Stark at its premises …primarily for the purpose of processing Stark’s oil for sale. … Bruce Power’s nuclear power facility … contract with Areva … [was a] situation... similar to that of the seismic equipment in Capilano International, in that Stark expected to bring TMT 4 back to its premises at Bailey’s Brook and continue primarily to process its own oil for sale, which it did. … [G]iven that the contract between Stark and Areva was only for 10 months, and given that the expected working life of TMT 5 would undoubtedly have been far greater than that, I find that the oil processing equipment in TMT 5 also comes within the principle established by Capilano International. ...

When a substantial deficiency in shareholders’ equity subsequently emerged, a negotiated Settlement Agreement concluded more than a year after the sale reduced the sale price by $0.5 million (to $15.5 million), increased the portion of the sale price payable under the reverse earn-out to $3 million – and provided that the vendors would reimburse a further portion of the sale price out of amounts received by them under the earn-out. ... See summary under s. 54 – proceeds of disposition – para. (a). ...

When a substantial deficiency in shareholders’ equity subsequently emerged, a negotiated Settlement Agreement concluded more than a year after the sale reduced the sale price by $0.5 million (to $15.5 million), increased the portion of the sale price payable under the reverse earn-out to $3 million – and provided that the vendors would reimburse a further portion of the sale price out of amounts received by them under the earn-out. ... See summary under s. 54 – proceeds of disposition – para. (a). ...

The Queen, 2018 TCC 144-- summary under Person Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Person person includes an heir of the person irrespective of also being a legal representative The definition of a “person” indicates that such word “includes … the heirs, executors … or other legal representatives of such a person.” ... She rejected the Crown’s argument that, in order to have this ability, the heir was required by the quoted wording to have been an heir who was also a legal representative, stating (at paras. 38, 44): [T]he word “heir” found in the definition of “person”, the meaning of which is determined in accordance with the applicable private law, does not necessarily have the same meaning as the word “heir” found in the definition of “legal representative of a taxpayer” as defined under subsection 248(1): in order for an “heir” to be a “legal representative of a taxpayer” under that latter definition, the heir must administer, wind-up, control or deal in a representative or fiduciary capacity with the property of the Estate. … Parliament cannot have intended that an assessment be immune to a judicial challenge. ...

. … The Minister must still consider … the three criteria he is mandated to consider in subsection 207.06(2) … to discharge his discretionary duty. ...

. … Before 2007 … it would appear that the risk borne by Visa Canada was almost entirely non-existent, with the risk instead largely being borne by Visa International and the issuing financial institutions. ... …Proposed subsection 4(1) of the Regulations stipulates that a "person at risk" does not include a person who becomes at risk solely through the provision of a clearing, settlement or authorization service. … [O]therwise taxable administrative services, such as those provided in respect of credit card transactions, do not fall within the definition of a "financial service" only because the service provider agrees to assume the remote risk of honouring the payment authorized under the credit transaction in the event of a failure by the relevant financial institution. ...

. … Justice Sharlow … [in Arnaud] concluded that paragraph 146(9)(b) did not apply to the case before her since there was no collateral arrangement. … [T]he appellants here did not enter into any collateral agreement that would have allowed them to recover their loss in whole or in part. ...

In finding that the base payments made in its 1999 to 2002 taxation years did not satisfy the requirement under s. 18(1)(a) of having been incurred for the purpose of producing income from the taxpayer’s business, Owen J stated (at para. 40) that an “expenditure of the income that has been determined for a taxation period cannot be incurred as part of the process of earning that income” and that it should be considered in this regard “that the base payment only arises after the conclusion of the producer’s income earning process in respect of potash subject to the base payment tax” (para. 66) given that “[t]o compute the amount of a base payment for a year, a producer must first compute its profits for that year” (para. 64) and that “Liability for a base payment will exist only in respect of potash that has been “sold or otherwise disposed of” by a producer … [i.e.,] potash … [that] is no longer capable of producing income for the producer” (para. 65). ... The Saskatchewan legislature simply chose in the case of the base payment to substitute quantity of potash as a proxy for income to ensure that a minimum amount of tax would be collected in respect of such potash even if the producer did not have profits for the year …. ...