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. … [I]n Daishowa-Marubeni …Nadon J.A. [stated]: … if the parties to an agreement attribute a value to a future liability, then the Minister is entitled to add this amount to the vendor's proceeds of disposition- whether or not the liability assumed by the purchaser is contingent or absolute. ...

The Trustees acknowledge that this commitment … does not constitute a delegation of their fiduciary powers. … If the Trustees or any of them disagree with the directives received from the Rémillard Brothers, they must then resign …. ... Article 1275 of the Civil Code of Quebec (the CCQ) provided: The … beneficiary may be a trustee but he shall act jointly with a trustee who is neither the settlor nor a beneficiary. ... However, he went on to find (at paras. 83, 104), in light of the testimony that the independent trustees, although consulting with the Rémillard Brothers, had in fact been making the trust decisions: Even if clauses 2.1 and 2.2 of the Agreement were contrary to the trust deed and Article 1275 of the CCQ … the Court concludes based on the preponderance of the evidence submitted that the Rémillard brothers did not act as trustees or “de facto trustees.” … [D]espite the Agreement, the Rémillard brothers did not, in fact, usurp the trustees' powers. ...

Other than this table, the appellant did not file supporting documents regarding the percentages set out therein, be they time sheets, SR&ED progress reports, correspondence, minutes of meetings, internal notes or emails related to these tasks, nor did it … call any of the employees from these two groups as witnesses to support these percentages …. The Court found no reviewable error in the finding below that the taxpayer had thus failed to “demolish” the ARQ assessments by making out a prima facie case, that the ARQ’s premise — of the taxpayer not having shown that the reported portions of each employee’s salary could reasonably be attributed to the prosecution of SR&ED — was false. ...

Callidus indicated that the “proposal provisions in the BIA serve … the same remedial purpose as those in the CCCA – i.e., the financial rehabilitation of an insolvent corporate debtor” and “to the extent possible, the two statutes should be treated in a harmonized fashion” (para. 46). Regarding BIA s. 50.6(3), which was the basis of the “judge’s power to establish the rank of the charge to secure an interim loan” (para. 49), and provided that the “court may order that the … charge rank in priority over the claim of any secured creditor,” the arguments of Attorney General that this provision had no application because s. 227(4.1) did not create a security interest, “it would seem nonsensical in the overall scheme of the BIA that a court could order that the interim lending charge take priority over the claim of any hypothecary or mortgage creditor but not over the claim of an unsecured creditor benefiting from a sui generis non-proprietary right akin to a floating charge, that is, the ITA Deemed Trust” (para. 51). ...

Although commercial gambling was not governed by specific VAT provisions, the jurisprudence had recognized (para. 9): “It is … only the net sum retained by the promoter after deduction of winnings which may be included in the taxable amount for VAT purposes.” ... Lord Legatt stated (at para. 48): What is required … is a change in the consideration actually received by the supplier. … All that has happened is that the taxpayer has had second thoughts about how the consideration received at the time of the supply should be analysed for tax purposes. Before so concluding, he noted (at para. 30) that it was “clear that there can be only one correct method of calculating the taxable element of fees charged to customers for playing cash bingo and … this was the session by session method and not the game by game method.” ...

. … Second, the legislator was careful to add "including guarantees or rights of set-off /y compris les garanties et droits de compensation". … The word "guarantees" must be taken in its broad sense, which includes suretyship. ... As for "rights of set-off /droits de compensation", the AGC is right to point out that these are personal rights. … Third, the [Finance] Explanatory Notes to the Regulations support this interpretation. … Gagné JCA went on to agree (at para. 44) with the essentially undisputed point that all the payments of interest (as well as principal) on the loan after the default date (July 15, 2014) reduced the PSI of the Caisse. ...

Ontario (Finance), 2007 CanLII 4786 (ON SC)-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) “use” and “consumption” have separate but similar meanings S. 2(1) of the Retail Sales Tax Act (Ont.) imposed tax on “every purchaser of tangible personal property … in respect of the consumption and use thereof….” ... Low J stated (at paras. 12-13, 15): [O]n the plain and ordinary meaning of the word “use”, … the appellant is the user of repair parts. The appellant is in the warranty business. … How does the appellant go about its business? ...

The Court dismissed the appeal, stating (at paras 10 and 16-17): [W]aiver form T2029 “bears the insignia of the … [Canada Revenue Agency (“CRA”)] and the Government of Canada and … is regularly used by the CRA.” ... Finally, we agree … that advice …from government agencies under freedom of information type legislation and a statement in the respondent’s motion factum did not amount to calling into question form T2029 as a prescribed form. ...

Vadnais' report, which contains a multitude of photographs, taken on August 5, 2015 … clearly indicates that 35 out of 88 units were not ready for rental. … The report also indicates that a significant portion of the underground parking garage was used to store materials and equipment such as, for example, bathroom vanities, kitchen countertops and equipment, etc. … Although the rule of thumb of 90% of the costs incurred may be appropriate in the vast majority of cases, for formulating, without further effort, an equivalence between a specific percentage of costs incurred and the concept of a "substantially completed" building, this does not seem justified under these circumstances. ...

Other than this table, the appellant did not file supporting documents regarding the percentages set out therein, be they time sheets, SR&ED progress reports, correspondence, minutes of meetings, internal notes or emails related to these tasks, nor did it … call any of the employees from these two groups as witnesses to support these percentages …. The Court went on to confirm the finding in the Court of Quebec find that the taxpayer had not “demolished” the basis for the assessments by demonstrating, “on a prima facie basis, that the respondent’s premise — i.e., that the appellant had not shown that the reported portions of each employee’s salary could reasonably be attributed to the prosecution of SR&ED — was false” (para. 25). ...