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. … Even if the supply provided by Zomaron to the Processors involved services of a promotional nature, since these do not represent the predominant element of the supply, paragraph (r.4) has no application …. ...

In finding that the taxpayer’s claimed losses (except for an overstatement of the 2002 loss due to an “egregious error” – for which a gross negligence penalty was sustained) were fully deductible, Spiro J noted- in responding to a Crown submission based on the trading consistently generating small economic losses, so that there was no source of income – that Stewart established that “provided that one’s activity is clearly commercial, and that no personal element is involved, there is a source of income” (para. 201) and made “it clear that there is no ‘sufficiency’ test” (para. 209). ...

However, the taxpayer (a Canadian resident with a French rental property), like others, was granted transitional relief so that in 2019 she received a tax credit from the French government equal to the French tax otherwise payable by her on her 2018 income – so that in 2019 she only had to pay the current tax on her 2019 rental income. ... The Tax Convention refers to income, regardless of when the tax is to be paid to or collected by the tax authorities. … Thus, since Mr. ...

Paul (together with Nancy about ¼ of the time) used a 36-foot boat, designed as a “pleasure craft,” to stay at other marinas and at boat shows, where he would mingle socially with the boaters and promote the use of the C.A.B. marina (as well as operating a promotional booth, when at a boat show). ... Boyle J stated (at paras. 20, 22): CRA has not been allowed by the courts to simply second-guess a business’s marketing strategy or efforts, even if they turn out to be unsuccessful in generating revenue. … Once it is established that business marketing activities were bona fide and primarily undertaken for business purposes, and that the expenses were themselves reasonable, it does not matter that the marketing involves socializing with clients, potential clients and/or other persons or entities relevant to its business. ...

Hogan J noted (at paras. 62, 70) that the “the Bundle of Rights … enabled CIBC to sell financial products and services” by “allow[ing] CIBC to tap into LCL’s loyal and extensive customer base.” ... For example, it could exclude from the “financial service” definition “property … that is delivered or made available to” CIBC “in conjunction with” CIBC selling PCF Products to new clients whom it recruited pursuant to the PCF Agreements (if we assume that such contractual rights are the predominant elements of the PC Bank Supply). ...

The word document [“record” in English] is [broadly] defined in subsection 123(1) …. ... The Court considers this testimony to be credible …. Appellant had therefore obtained this information prior to the filing of the 2015 annual return containing the claimed ITC. ...

. … [A] GST registrant should be entitled to determine its input tax credits on the basis of information in its possession without having to resort to hiring expensive third parties, such as valuators or, as I will discuss, engineers to measure spaces on its ships or experts to try to determine what percentage of fuel is consumed to propel a ship and what percentage is consumed to produce electricity, heat or hot water. … He also noted (at para. 126) that the taxpayer’s method appeared to be better than the output-based method used by it in earlier reporting periods and accepted by CRA. ...

This amounts to wilful blindness …. She briefly found in the alternative that he had been grossly negligent, stating (at para. 83): Failure to review a return at all is suffic[ient] to find that any false statements in the Return are made in circumstances amounting to gross negligence …. ...

However, that is all it does …. There is nothing in the wording of subsection 13(31) that creates the fiction of the Limited Partnership having a year-end prior to February 1, 2005 …. ...

In concluding that Gorgis had satisfied s. 254(2)(g)(i) through being the first occupant of the home “as a place of residence,” Cook J found that: Gorgis’ staying there two to four nights a week was consistent with it being a place of residence; Although he only moved in with “six pieces of luggage and a limited assortment of furniture … there [was] no indication that he had significant personal belongings elsewhere” (para. 26); and “His use of the Property was more than transitory – he was the sole occupant of the Property for one year and he still owns it and has use of the basement” (para. 27). ...