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. … For tax purposes, a bare trust is considered a non-entity in the sense that a beneficiary as principal, is considered to deal directly with property through the trustee as agent or nominee…. … Since I have concluded that Dr. ...

. … Subsection 323(1) of the ETA is an exemption from the common law and applies only to directors. ... However, …the legislator … limited the application of subsection 323(6) to the office of director. ...

Nor was there an abuse of the partnership income allocation provisions of ss. 103 and 96 – it was totally conventional that close to 100% of the income of the LP was allocated to the corporation (Nuinsco) which was the limited partner at the partnership (HLP) year end. ... The income reallocated to Partnerco through GAAR did not change from ignoring the deemed year end. … ...

In finding that the appellant was not entitled to claim input tax credits given the failure of the invoices (for amounts over $150) provided to him to satisfy the requirements of the Input Tax Credit Information (GST/HST) Regulations (and after underlining the requirement in s. 3(c)(iv) thereof that there be a “description of each supply sufficient to identify it”), Bédard J. stated (at paras. 23-24): Since the purpose of paragraph 169(4)(a) of the ETA and the Regulations is to protect the consolidated revenue fund against both fraudulent and innocent incursions … a description is sufficient when it allows the Agency to identify the work performed by the suppliers. ... [In] all the invoices submitted … at least one mandatory element of information is missing. ...

. … [A] contextual and purposive analysis…leads to the conclusion that the words “loan corporation” as used in the Attribution Regulations…mean a corporation whose principal business is the making of loans…. ... In my view, if Parliament had intended such a result it would have added that specific condition to the legislation. … Words and Phrases loan corporation ...

In allowing the taxpayer’s appeal, D’Arcy J stated (at paras 31, 32, and 33): … [T]he Appellant paid Gary McCrea and Tom McCrea wages of $38,880 solely for the work Gary McCrea and Tom McCrea performed conducting SR&ED. ... Counsel for the Respondent argued that… Gary McCrea and Tom McCrea did not receive any compensation for the significant time they spent “performing director or management activities” for the Appellant. … As the controlling shareholders and managing directors of the Appellant, they chose to receive dividends in lieu of salary and/or bonuses. ...

In preparing his 1995 and 1999 returns, he reported his contributions, but failed to deduct them – but thought that he had. ... After confirming the taxpayer’s Part X.1 tax liability and after quoting (at para. 26) a statement in Corporation de l’École Polytechnique v The Queen, 2004 FCA 127 that a due diligence defence is established if “the person believed on reasonable grounds in a non-existent state of facts which, if it had existed, would have made his or her act or omission innocent,” Sommerfeldt J went on to find that the s. 162(1) penalties should be cancelled, stating (at paras 11, and 27): … I am of the view that his failure to deduct the contributed amounts, which was unbeknown to him, was due to innocent and reasonable inadvertence. ...

After noting that, on this basis, the Canadian employment income was approximately 60% of the taxpayer’s income for 2014, he stated (at para 18-19): … [C]ases have relied on percentages as low as 76% to be considered substantially all. ... Kenny has been caught by the application of section 118.94 of the Act and is not entitled to tax credits beyond what the Minister has allowed. … Words and Phrases substantially all ...

. … [T]he builder simply cannot grant the credit without having already received the prescribed form of the purchaser as described in paragraph 254(4)(c). ... After indicating that there was an imperative requirement in the wording of s. 254(5)(a) that the builder forward the purchaser forms with its return claiming the rebate amount, she stated (at para. 64): Consequently, the builder who has not conformed with the requirements of s. 254(5)(a) cannot deduct an amount in this regard in the computation of its net tax …. ...

. … There is no doubt in my mind that the epinephrine and its salts and the anesthetic solutions containing epinephrine supplied by the appellant come within the definition of the term “drug” as defined under the Canadian Food and Drugs Act … However, drugs which have epinephrine as their sole active ingredient are different from those that have epinephrine combined with another active ingredient, such as the anesthetics in issue. ...