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. … [O]n my interpretation a taxpayer in response to a query need only produce the agreement of purchase and sale to show the legal acquirer of the complex and easily obtained personal documents, such as utility bills, other standard invoices, and drivers’ licences to show who is personally residing in the complex. On my colleague’s view … [s]uddenly a straightforward verification exercise morphs into a sprawling examination for discovery. ...

Webb JA found that the s. 96(1.1) distribution did not satisfy the applicable requirement in s. 14 of the CPP Act that it be “his income for the year from all businesses … carried on by him” (he instead was retired). He stated (at para. 30): The deeming rule in subsection 96(1.1) … only provides that Mr. ...

Webb JA found that the s. 96(1.1) distribution did not satisfy the applicable requirement in s. 14 of the CPP Act that it be “his income for the year from all businesses … carried on by him” (he instead was retired). ... As a result he was not carrying on a business in common with other partners of Deloitte & Touche LLP at any time in 2008 for the purposes of the CPP. ...

. … In this case, the Tax Court found that the relevant documents contained much more than financial information, as was the case in Boulangerie St-Augustin …. ...

. … [I]n order to have a “liquidated money demand, recoverable by action” one must know the identity of the debtor and the amount owed …. ...

. … [A]n ambiguity does arise from a broader examination of the ETA as to how subsections 132(3) and 150(1) interact. The task when confronted with seemingly conflicting provisions is to determine whether they can be made to work coherently in a manner which gives effect to the statutory scheme …. ...

In rejecting the CRA position in this regard, Webb JA stated (at para. 28): The Crown’s interpretation … [is] that all ingredients that are included in the packaged product must be agricultural or plant products grown in Canada, except those that are permitted to be added by the CRA, on the basis that they are “incidental”. This would result in a delegation of authority to the CRA to decide what wine will qualify for the exemption. … [I]t would not have been the intent of Parliament to implicitly delegate this authority to the CRA. ...

This is … a legal error. As stated [in Shell]: “This Court has consistently held that courts must therefore be cautious before finding within the clear provisions of the [ITA] an unexpressed legislative intention...” …. ...

Laskin JA found that the Rules merely required the Minister to produce the documents which were in the hands of the decision-maker when the decision was made – and not to provide various other requested documents (e.g., the constating documents of all registered CAAAs at the time of the decision). However, the affidavit of the CRA decision maker stated that “all relevant materials upon which the CRA relied … have been produced.” ...

The Tax Court found that the transferred assets represented about 68% of the fair market value of the assets of the Tissue Division – and perhaps significantly less, given that some of the Tissue Division assets had not been valued. Accordingly, the requirement of s. 54.2- that all or substantially all of the assets of the business have been transferred to a corporation – had not been met, so that s. 54.2 did not deem the gain on the share sale to be a capital gain. ...