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In the case of a lease, there can be no assignment of the lease to the limited partnership – it must be assigned to the general partner. ...

. … It is therefore necessary to consider, on a document-by-document basis, whether each Sample Document is subject to legal professional privilege. ...

Agence du revenu du Québec, 2022 QCCQ 1175-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Contract Payment- Paragraph (a) expenditures under an agreement to develop software for a 3rd party pursuant to its specifications were not associated with contract payments The taxpayer (“CS Canada”), which carried on a business of developing software for use in the aeronautics industry, entered into a “long term purchase agreement” with a third party (“Pratt & Whitney” or “P&W”) for the sale to it of control system software. ...

The Court found that the application judge- who had noted the contrast between the above representation, and other representations and warranties in the SPA which were limited to the knowledge of the sellers – had reasonably concluded that such representation could be untrue as of the time of closing even if the prospect of reassessment was not reasonably expected by FQM. ...

Before finding that the memo was potentially relevant and should be produced, St-Hillaire J noted that there was no accountant-client privilege, stating (at para. 59, TaxInterpretations translation): According to the appellant, if such advice were to be systematically disclosed, the quality of communication between accountants and their clients, and compliance with the Act would be reduced …. ...

Gestion Roy was the owner of such policies (entitling it to the cash surrender value of the policies at any time), so that it was “enriched” when the premiums were paid by R3D (with Boivin JA stating in this regard, at para. 6, TaxInterpretations translation, that “the appellants received an advantage in that for years they owned policies with a total death benefit of $20,000,000 and all the rights attached to them, without having to pay premiums”) – and it was irrelevant to this point that, in fact, Gestion Roy never received any distribution on its policies. ...

. … The facts of Mr Arrbab's case are an unfortunate illustration of the reality that only a right of recourse to an independent tribunal may provide effective protection against failures of administration, including a failure to recognise that time ought to be extended. ...

An RVO advances the same goals as an AVO — albeit by employing a different transaction structure. ...

. … Thus, the return of the unit in each case was to reflect that the original taxable supply was nullified, rather than representing a further taxable supply, so that the application of the s. 332 equivalent was confirmed. ...

In allowing the Crown’s appeal, Skolrood JA referred to his statement in GFL (at para. 60): I endorse the principle … in Preston that tax assumptions containing statements of mixed fact and law will not be invalidated simply on that basis if the factual underpinnings are clearly stated, there is no dispute about the legal principles and no prejudice results. ...