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. … That a person may not be aware at an earlier point in time what the criteria of liability may subsequently be made to apply to that earlier point in time does not make the legislation arbitrary or incontestable…. ...

The Court concluded (at para. 16, TaxInterpretations translation): [I]f SARL Google France had the character of dependent agent within the meaning of (c) of paragraph 9 of Article 2 of the French-Irish Tax Convention, it nonetheless did not exercise, in the years under litigation, the power to bind Google Ireland Limited in commercial relations respecting the transactions constituting the activities of the latter corporation; it follows from this that the Service was incorrect in considering that Google Ireland Limited exercised, through a permanent establishment that was formed by SARL Google France, an activity in France within the meaning of section 182 of the General Income Tax Code …. ...

It follows that, assuming that each ‘variation of income’ resolution was authorised by the relevant trust deed, the applicant was not “presently entitled” to a share of the net income of the trust estate … for [that] year…. ...

Before dismissing DGGMC’s appeal, she stated (at paras. 51-53, Tax Interpretations translation): Here we are not concerned with … a seizure outside of Quebec which, it is true, could require the seizing party to approach an authority of the foreign State with a view to obtaining its collaboration in order to proceed. ...

Thus, the right to deduct VAT charged on the acquisition of input goods or services presupposes that the expenditure incurred in acquiring them was a component of the cost of the output transactions that gave rise to the right to deduct … [36] In this case, in view of the fact that, first, a share issue is an operation not falling within the scope of the [Directive] and, second, that operation was carried out by Kretztechnik in order to increase its capital for the benefit of its economic activity in general, it must be considered that the costs of the supplies acquired by that company in connection with the operation concerned form part of its overheads and are therefore, as such, component parts of the price of its products. ...

. … Mr. Demers is an experienced director. Nothing permitted him to believe that the cosmetic changes made to the structure of the Corporation sufficed to change its tax obligations and to terminate its obligations to collect and remit the source deductions for personnel. ...

.” … [T]he judge concluded that the evidence presented by the Agency did not support the hypothesis that a business other than the subcontractors indicated in the invoices had transacted with Mr. ...

. … Words and Phrases Harman obligation ...

. … A parent of a municipal entity is not entitled to gain an advantage over its private competitors by arranging its subsidiaries’ affairs in a way that causes a hypothetical arm’s length loan to appear riskier than it would have been had any reasonable municipal entity actually gone into the market to borrow the funds. ...

The two issues were "the taxability issue"--whether the settlement sum was taxable employment income as "payments and other benefits which are received [by the relevant person] directly or indirectly in consideration or in consequence of, or otherwise in connection with- (a) the termination of a person's employment"; and, if so, "the exemption issue"--whether the settlement sum (or any part of it) was taken out of the above charge to tax by a statutory exemption (“s. 406”) for a payment provided "on account of injury to … an employee", the alleged injury being the injury to the taxpayer's feelings sustained in the context of his age discrimination claim. ...