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. … I cannot find that the loan was repaid before the end of [the corporation’s] 1988 taxation year. ...

The Queen, 2022 TCC 34-- summary under Legal Representative Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Legal Representative a de facto executor was a legal representative Wong J rejected the taxpayer’s submissions that he had renounced his executorship shortly after being appointed and that his subsequent acts in jointly (with his brother) transferring estate property to his daughter were performed qua a trustee de son tort and not as an executor – so that he should not have been assessed under s. 159(3) for unpaid estate taxes given their failure to obtain a clearance certificate. ...

Russell J indicated that, in light inter alia of the principle of judicial comity, he would follow the same Kuchta approach (notwithstanding that Kuchta might be technically a nullity as it had been decided by a substituted judge – see High-Crest). ...

Sommerfeldt J found on the evidence (even though the vendors were not parties to the case) that the vendors had never occupied the home as a residence and had sold the home as an adventure in the nature of trade – so that they were builders, and the sale was subject to HST. ...

. … The submission, dated two weeks after the notice of reassessment, while not perfectly detailed, was sufficient to initiate the objection process responsive to an audit and conclusions already in active dispute. ...

Had he believed he was not a shareholder of HGSL as of that date, he could have applied to rectify the register under section 168 of the NBBCA …. ...

Unfortunately, s. 56(1)(u)(ii) deemed the ODSP payments to be the income of the higher-income spouse (herself) – so that on a literal reading of the combined effect of s. 122.62(5)(b) and s. 56(1)(u)(ii), her family income included not only her actual income but also the income attributed to her under s. 56(1)(u)(ii). ...

The King, 2023 TCC 173 (Informal Procedure)-- summary under Qualifying Group Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Group three corporations wholly-owned by an individual could not make a s. 156 election In finding that three corporations which had the same individual as their sole shareholder did not qualify as specified members of a qualifying group, so that they were ineligible to make the joint election pursuant to s. 156(2), Jorré J noted that, in the case of corporations, the “qualifying group” definition referred to ”a group of corporations, each member of which is closely related … [per s. 128] to each other member of the group,” and then stated (at paras. 17-18, TaxInterpretations translation): In accordance with section 128, only corporations controlled by a corporation may be closely related. ...

However, the Minister had not pleaded backdating- only that the appellant had continued as a director – nor did she plead lack of due diligence. ...

After finding that the taxpayers were not ordinarily resident in Canada, Boyle J. found (at para. 43) that this factual situation "clearly meets the intermittent, temporary visit or stay parts of the meaning given to sojourn... in Thomson " and that "a business trip is one of the specific examples set out by Professors Hogg and McGee of sojourning. ...