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CRA denied the taxpayer’s request four years later for a refund of this amount on the grounds that this request had not been made within the required three-year period – and in the resulting 2014 reassessment it in fact denied some deductions/credits that had been initially allowed in its 2009 assessment. ...

. … The focus of [s. 20(1)(c)] is the current use of the borrowed money, not on the current ownership status of the property initially acquired with it. ...

As subsection 123(1) makes clear, this exceptional treatment is restricted to non-resident insurers …. ...

Boivin JA stated (at para. 7): [These] remarks … were ill-considered. ...

After finding that this agreement bound the Crown insofar as the first taxation year was concerned, Woods JA noted that the Tax Court order giving effect to the agreement had the likely effect of not only reducing CBS’ tax for its taxation year ended March 7, 2007 but of also increasing tax for the subsequent taxation year – and then addressed the issue as to whether such an increase in tax for one of the taxation years was permissible under the ITA, and stated, in the affirmative (paras. 44-45): It is significant that, in both Harris and Last, it was the Crown and not the taxpayer that sought an increase in tax. ...

. … Even on a broad interpretation of paragraph 12(a), the appellant did not ship the jewellery to a destination outside of Canada that was specified in a contract of carriage. ...

. … [T]he letter agreement between Pangaea and Thomvest is a “restrictive covenant,” as defined, because the agreement is intended to affect the provision of property by Pangaea by having an effect on its disposition. ...

. … [T]he letter agreement between Pangaea and Thomvest is a “restrictive covenant,” as defined, because the agreement is intended to affect the provision of property by Pangaea by having an effect on its disposition. ...

Here, the judge’s discretion was exercised consistent with the objective of this rule …. ...

., 2020 FCA 64-- summary under Subsection 18.1(2) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18.1- Subsection 18.1(2) CBSA required to revisit an adverse decision due to its failure to explain a departure from past practices In a specialized customs tariff remission context, De Montigny JA agreed with Zinn J of the Federal Court that a decision of the CBSA- to deny a request of a clothing manufacturer (Honey Fashion) to have the name of the importer of record changed from the actual importer to that of Honey Fashion (in order that Honey Fashion could generate remission claims for the importations in question) – should be reversed given that the CBSA decision did not give any explanation as to why it was not following its practice in previous such claims of allowing such a name change. ...