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The test is whether … may one say that the building was renovated sufficiently enough that all or substantially all of the building has been removed or replaced: Camiré v. ...

Agence du revenu du Québec, 2025 QCCQ 1127-- summary under Subsection 45(1) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1) the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use In 1981, the taxpayers (10 individuals), acquired as co-owners two adjoining rental buildings containing a total of 82 apartments, with their respective undivided interests in such properties ranging from 2.27% to 29.2%. ...

After this granting of an earlier effective registration date, 353 then refiled the returns for the initial three quarters, and CRA then promptly assessed 353’s returns – but apparently not the initial three quarters. ...

In rejecting this position, Monaghan JA noted (at para. 303) that s. 56(1) provides that "there shall be included in computing the income of a taxpayer for a taxation year" the amount described in that section, including "amounts required by section 146 in respect of a [RRSP] … to be included in computing the taxpayer's income for the year," and s. 146(10), in turn, stated that where an RRSP acquired a non-qualified investment, the acquisition date value "shall be included in computing the income for the year of the taxpayer who is the annuitant. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...

(a)(iii)(B) includes a single individual, so it did not matter that there was only one tenant during the relevant period (para. 11); in the situation, for example, where "two individuals occupy the unit – one for a year and the other for six months –...on the basis that the plural includes the singular, the unit will qualify...by applying the test to the one individual who does occupy the unit for the whole year" (para. 12) "if there is only one occupant of a unit, in order for the unit to qualify based on the actual use test, the unit will have to be occupied by the same individual for a full period of one year (or the shorter period of time contemplated by this clause [((B)])" (para. 20) the phrase "place of residence of individuals" in s. ...

(The taxpayer testified that he spent $104,719 to install a gravel road for ¾ of the property length in order to free up a pick-up truck that had become stuck in peat.) ...

Hershfield J referred (at para. 91) to this being from the perspective of Mall Co a " quid pro quo from ICBC to forego its entitlement against Tech BC. ...

. … CIBC’s answer to question 5591 merely states that…legal advice informed its position. ...

. … [T]he fact that Chapter 2 was introduced partly for the purpose of forestalling tax avoidance schemes self-evidently makes it difficult to attribute to Parliament an intention that it should apply to schemes which were carefully crafted to fall within its scope, purely for the purpose of tax avoidance. ...