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. … It follows that the assignment of these leasehold interests is a taxable supply to the purchasers, as Polygon is not deemed to self-supply in accordance with the provisions of paragraph 191(1)(b) of the Act, and the assignment of a lease is not an exempt supply under section 5.1 of Part I of Schedule V …. ...

De Montigny JA stated (at para. 8): … While I accept that, generally speaking, the CRA’s treatment of other taxpayers is irrelevant when assessing whether to grant discretionary relief to a given individual, the Judge could reasonably infer … that the CRA’s decision not to recommend remission was premised, at least in part, on the respondent not being in similar circumstances as the SDL employees. ...

. … Deeming provisions create legal fictions. They assume things to exist even when they do not in reality—like, for example, the supply of a home that is not yet constructed. … Other elements found in the text, context and purpose of the statute support the interpretation that supply means the signing of an agreement of purchase and sale and not a transfer of beneficial ownership. ...

. … [O]n my interpretation a taxpayer in response to a query need only produce the agreement of purchase and sale to show the legal acquirer of the complex and easily obtained personal documents, such as utility bills, other standard invoices, and drivers’ licences to show who is personally residing in the complex. On my colleague’s view … [s]uddenly a straightforward verification exercise morphs into a sprawling examination for discovery. ...

Webb JA found that the s. 96(1.1) distribution did not satisfy the applicable requirement in s. 14 of the CPP Act that it be “his income for the year from all businesses … carried on by him” (he instead was retired). He stated (at para. 30): The deeming rule in subsection 96(1.1) … only provides that Mr. ...

Webb JA found that the s. 96(1.1) distribution did not satisfy the applicable requirement in s. 14 of the CPP Act that it be “his income for the year from all businesses … carried on by him” (he instead was retired). ... As a result he was not carrying on a business in common with other partners of Deloitte & Touche LLP at any time in 2008 for the purposes of the CPP. ...

. … In this case, the Tax Court found that the relevant documents contained much more than financial information, as was the case in Boulangerie St-Augustin …. ...

. … [I]n order to have a “liquidated money demand, recoverable by action” one must know the identity of the debtor and the amount owed …. ...

. … [A]n ambiguity does arise from a broader examination of the ETA as to how subsections 132(3) and 150(1) interact. The task when confronted with seemingly conflicting provisions is to determine whether they can be made to work coherently in a manner which gives effect to the statutory scheme …. ...

In rejecting the CRA position in this regard, Webb JA stated (at para. 28): The Crown’s interpretation … [is] that all ingredients that are included in the packaged product must be agricultural or plant products grown in Canada, except those that are permitted to be added by the CRA, on the basis that they are “incidental”. This would result in a delegation of authority to the CRA to decide what wine will qualify for the exemption. … [I]t would not have been the intent of Parliament to implicitly delegate this authority to the CRA. ...