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. … Mr. Davis’ residency in Canada before May 9, 2013 was preparatory to disengaging from the U.S. and permanently ceasing to be a resident after May 9, 2013. ... Davis … habitually lived in the U.S. based upon frequentcy, duration and regularity. ...

He went on to state (at paras. 32, 35): This case demonstrates that there is clearly a gap in section 160 … [but s]imply amending section 160 to cause it to cover the non-arm’s length provision of services may have undesired consequences. … If a tax debtor spent all of his or her free time caring for his or her aging parents, would the Minister assess the parents for the fair market value of that care? ...

. … [T]he definition of “legal representative of a taxpayer” found in subsection 248(1) does not apply to determine who is a “person” under the Act. … …Mrs. ...

Toca, 2018 BCCA 191 …. Although there is no evidence in this case that IPG provided any consideration to Houweling in return for his agreement to wait for payment of the loan, there is nothing to suggest that IPG exerted any economic pressure on Houweling to obtain the variation in the loan agreement and that there are no public policy reasons that would render the agreement unenforceable. … As a result, there was no amount owing by IPG to Houweling during the year that followed the issuance of the RTP and therefore no amount owing by IPG under the ITA as a result of its failure to make any payment to the Minister pursuant to the RTP. ...

More particularly, he stated (at para. 238) that the quoted statutory exclusion was “grounded in an underlying rationale that … focus[es] on competitiveness,” and that “in looking at both aspects of a foreign bank’s business [namely] the receipt of funds and use of funds, there should be emphasis on the receipt side as that is where one would expect to find the competition element.” Here, virtually all of GBL’s funds came from non-arm’s length parties [there being no discussion as to who the receipt of equity funding can be part of the conduct of a business] – and, turning to the use of its funds, the purchases of the short-term debt were impressed with their character of researching the best return for a non-arm’s length party, the distributor loans “were effectively handed over to GBL by Loblaw” (para. 243), the intercompany loans clearly were with non-arm’s length persons and “even the swap activity has a considerable element of conducting business with non-arm’s length person, as the swaps were subject to Loblaw derivative policies” (para. 247). ...

Graham J found that "the test in section 54.2 is intended to be a somewhat flexible test but … there is no reason not to consider the fair market value of the assets when applying the test.” From the FMV perspective, the transferred assets represented about 68% of the assets of the Tissue Division – and perhaps significantly less, given that some of the Tissue Division assets had not been valued. ...

In finding that no interest or penalty was payable by virtue of the set-off rule in s. 228(6), D’Auray J stated (at paras. 36-38, TaxInterpretations translation): When a person files a GST return … “at any time” and it attaches to that return a rebate claim, the person is deemed “at that time” (in this case, September 28, 2015) to have made its payment and the Minister is is deemed “at that time” to have paid … an amount as a rebate. ...

I agree … and find that the object, spirit and purpose of subsection 111(5) is to target manipulation of losses of a corporation by a new person or group of persons, through effective control over the corporation’s actions. ... In allowing the appeal, he concluded (at para 166): … [T]he circumstances referred to by the Respondent do not, in my view, indicate that Matco had effective control over the majority of the voting shares of the Appellant prior to the IPO and I find that the Avoidance Transactions do not amount to abuse of subsection 256(8) and paragraph 251(5)(b) of the Act. ...

This cannot be said of the Oldco Note …. The consideration for the surrender or forgiveness of the valuable Newco Note was the surrender or forgiveness of the Oldco Note with nominal value. ... It is precisely “at the time” of transfer that the consideration proffered “at such time” was deficient …. ...

The respondent argues that … the buyers could not affect the legal position of Lohas, since the principal could not have contracted with Apple (para. 111).... … [A]ssuming the buyers purchases were in violation of Apple policy[,] at most this made the purchase contracts voidable and not void. ...