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Nonis continued to be an employee after his “termination” (albeit, with virtually non-existent duties), Bocock applied the principle (at para. 59) that, under “paragraph 4(1)(b) of the Act, if a taxpayer works partly in Canada and partly in another country in the same taxation year, the taxpayer’s taxable Canadian income for the year is the amount earned while working physically in Canada” – so that Mr. ...

These transactions depended in part on the appellants being considered to have acquired units of an income fund ("FMO") from another income fund ("TOM") (which in turn had purportedly acquired the FMO units from an RRSP in consideration for issuing TOM units to it) at a cost equaling the units’ FMV, followed immediately by a distribution to them of capital gains that had been realized by FMO – with that distribution not reducing the ACB of their units by virtue of s. 53(2)(h)(i.1)(A) and (B)((I). ...

These transactions depended in part on the appellants being considered to have transferred the acquired units of an income fund (“FMO”) at a cost equaling the units’ FMV followed immediately by a distribution to them of capital gains that had been realized by TOM – with that distribution not reducing the ACB of their units by virtue of s. 53(2)(h)(i.1)(A) and (B)((I). ...

Before concluding that 9267 was not entitled to the s. 231(1) credit, D’Auray J stated (at para. 42, TaxInterpretations translation): … 9267 did not remit GST on the taxable supply, i.e., on the sale of its domain names to 9210, when it filed its return. ...

. … Parliament does not want to grant a tax credit where the donor is not impoverished and the charity is not enriched. ...

In finding that, in those post-wind-up year, GMI was continuing to carry on the GNC business, Archambault J stated: … GNC’s primary purpose was to sell natural gas, and incidentally to supply services of converting vehicles to natural gas. ...

Spiro J stated (at para. 34): Having applied the criteria … in Moldowan, I find that each factor (other than time spent), weighs heavily in favour of the conclusion that the Appellant did not carry on his farm business with a reasonable expectation of profit. ...

Likewise there should not be liability for the three paragraph 162(7)(a) failure to file penalties, as the defence of due diligence has been established – that is, the appellant reasonably believed in a mistaken set of facts that if true would have made his act or omission to act innocent. ...

. … The Respondent’s egregious history of defaults and non-compliance in these appeals, that there is no alternative available that could reasonably be expected to cause the Respondent to now comply, and that this has caused prejudice to the Appellants, are reason enough to allow these appeals. ...

Smith J confirmed CRA’s inclusions in Gestion Roy’s income under s. 15(1) of the annual premium amounts paid on Gestion Roy’s policies given that it was the owner of such policies (entitling it to the cash surrender value of the policies at any time), so that it was “enriched” when the premiums were paid by R3D – and indicated that it was irrelevant to this point that, in fact, Gestion Roy never received any distribution on its policies. ...