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Commissioners for Her Majesty's Revenue and Customs, [2015] BTC 32, [2015] EWCA Civ 1036-- summary under Purpose Summary Under Tax Topics- Statutory Interpretation- Purpose purposive approach entails checking whether overall effect of transaction answers the statutory description Lewison LJ stated (at paras. 20, 50): The parties were largely content to rely on the discussion in Barclays Mercantile Business Finance Ltd v Mawson [2004] UKHL 51, [2005] 1 AC 684 …. ...

., after noting (at para. 101) that the French version of s. 152(4)(a)(i) rendered “misrepresentation” as “misrepresentation of facts ” and (at para. 102) that in Canada v. ...

Hesler CJQ found that their obligations to collect and remit taxes on their fuel sales did not violate the ancestral right to trade freely and openly as protected by s. 35(1) of the Constitution Act, 1982, stating (at para 42): There must… be a reasonable degree of continuity between the ancestral practice being invoked and the modern right being asserted… [T]he practice of trading objects to which the spiritual power symbolic of Orenda attached cannot be the basis of the modern right … to trade freely without hindrance. ...

The Petitioner was … present in India… for 41 days during 2008-09 for rendering the contract of service to IOCL. ...

The information laid before the issuing judge had not addressed any absence of an alternative solution – and Hilton JCA also chided the ARQ for failure to disclose the “material fact” that the law firm in question was acting for the client in the tax dispute with the ARQ. ...

. … Although Mr. RF works in the construction industry, this does not deprive him of the right to acquire and sell his principal residence if circumstances make it unavoidable or desirable, even if the transactions occur over a relatively short period of time. ...

. … The provision by the customer of the loan was the consideration for both the payment of interest and the provision of the banking services. ...

. … As I construe subsection 84(3), a corporation is deemed to have paid a dividend at the time of the acquisition of its shares and, even if the consideration for the shares acquired is payable over a considerable period of time, it must, for the purposes of income tax law, be regarded as being payable at the time of the acquisition. ...

Agence du revenu du Québec, 2018 QCCQ 9487-- summary under Subsection 296(1) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(1) QBCA did not provide that audit or other proceedings could be commenced against a dissolved corporation The ARQ commenced a QST audit of a corporation (Motostar) after its voluntary dissolution by its sole individual shareholder (Delia) and assessed Motostar for some unremitted QST – and then assessed Delia for the same amount under the Quebec equivalent of ETA s. 323(1) (and ITA s. 227.1(1).) ...

. … Irrespective of the applicable section of the Copyright Act, it is clear that Appellant was assessing the purchase of rights. ...