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The Funds argued that they were receiving an exempt financial service from Funding Corp – so that this arrangement in effect eliminated the GST or HST on the portion of the management fees that was assigned to Funding Corp. ...

[T]here is no evidence that shows that the Appellant conveyed a beneficial interest in the aforementioned shares prior to the completion of the purchase and sale arrangement with his family member … [B]ecause the Appellant’s wife and daughters did not have an interest in the 85 Class B, C and D common shares prior to the time they purchased them from the Appellant later on the same day, no benefit was conferred on them directly or indirectly as a consequence of the completion of the capital reorganization of MDPC. ...

. … Essentially, all of the factors outlined in Essa [[1993] OJ No 229]… favour the granting of this motion. ...

Paris J accepted that a corporation (“SVO”) had agreed to manage all of the buildings as well as the common areas as agent for all of the owners, notwithstanding that the taxpayer was only able to provide an unsigned copy of the management agreement – and also accepted that a parking area had subsequently been acquired by SVO as their agent notwithstanding the failure to locate any written agreement to this effect. ...

. … In the circumstances, I have two choices. I can either not allow Ms. ...

. … The contrary conclusion would strain the ordinary meaning of the words “equal or near equal”. ...

. … I have no hesitation in concluding that the benefit sought by Birchcliff from the amalgamation was to obtain the tax attributes, the losses, of Veracel. ...

. … [T]he respondent was required to demonstrate, on a preponderance of evidence, not only that a certificate specifying the amount for which the corporation was liable had been registered in the Federal Court, but also that that amount had been returned unsatisfied in whole or in part. ...

However, TSI filed a Notice of Discontinuance on May 2, 2016 and the appeal was deemed to be dismissed on June 24, 2016 pursuant to s. 16.2(2) of the Tax Court of Canada Act (the “ TCC Act”). ...

The Queen, 2018 TCC 83-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) two individuals jointly controlling a company were acting in concert respecting the payment of dividends A company (“PES,” or the “Operating Company”) providing electricians’ services initially was owned on a 50-50 basis by two individuals – Smith and Scott, who each was an officer and director, and with Smith overseeing the work at various sites and with Scott responsible for most financial matters. ...