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Regarding the Minister's argument that Article 13 was only included "for greater certainty," Sharlow J.A. stated: The OECD model conventions, including the Canada-Austria Income Tax Convention, generally have two purposes – the avoidance of double taxation and the prevention of fiscal evasion. ...

On appeal to the Court of Appeal, the Minister raised several new arguments, including that: the transactions were abusive of ss. 3, 4, 9 and 111, an underlying policy of which is that business loss claims should reflect actual losses; the taxpayer's purported losses were not business losses, given that the shares were not acquired as inventory or as part of and adventure or concern in the nature of trade (see "Rollover and other non-trading transactions "); and to the extent that the taxpayer had any losses, they were capital in nature. ...

. … If the payments were remuneration payable to Ms. Kirsten for her services, subsection 56(2) would not require the payments to be taxed in the hands of Mr. ...

" and that this condition was satisfied here given that the taxpayer's exercised control over Holiday 80. ...

., that it was not one or the other of those things, cannot be” – as was the case here as the taxpayer’s debenture purchase had effectively been admitted not to be an investment. ...

. … CRA…responded to Devon in relation to the merits of its submissions with respect to paragraphs 20(1)(b) and 20(1)(e)… and…in the notices of confirmation, stated that the basis of the objection included the argument that the predecessors of Devon should be entitled to a deduction under paragraph 20(1)(b)…. ...

., 2011 FC 224 …aff’d 2011 FCA 306 ….” ...

Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288-- summary under Section 82 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 82 inconsistent assessments of related taxpayers A Barbados corporation reported substantial profits from the sale of a herbicide to Canadian farmers, and deducted amounts paid to a non-arm’s length Canadian corporation (AgraCity – which was the taxpayer in the case) as service fees. ...

Canada, 2016 FCA 181-- summary under Sham Summary Under Tax Topics- General Concepts- Sham deceit of taxpayer was irrelevant to assessment – so that “sham” also was irrelevant The applicant (“Coast Capital”), which was the trustee of RRSPs and RRIFs, was assessed under s. 116(5) for failure to withhold on its purchase of shares (that were taxable Canadian property) of Canadian companies from non-resident vendors at prices which were substantially in excess of those shares' fair market value (with the result that the RRSPs and RRIFs were stripped of funds which ended up in offshore accounts or were applied to pay the fees of the "promoter. ...

. … [T]he treatment accorded to other productions does not create legitimate expectations for the respondent. ...