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. … [T]he letter agreement between Pangaea and Thomvest is a “restrictive covenant,” as defined, because the agreement is intended to affect the provision of property by Pangaea by having an effect on its disposition. ...

Here, the judge’s discretion was exercised consistent with the objective of this rule …. ...

., 2020 FCA 64-- summary under Subsection 18.1(2) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18.1- Subsection 18.1(2) CBSA required to revisit an adverse decision due to its failure to explain a departure from past practices In a specialized customs tariff remission context, De Montigny JA agreed with Zinn J of the Federal Court that a decision of the CBSA- to deny a request of a clothing manufacturer (Honey Fashion) to have the name of the importer of record changed from the actual importer to that of Honey Fashion (in order that Honey Fashion could generate remission claims for the importations in question) – should be reversed given that the CBSA decision did not give any explanation as to why it was not following its practice in previous such claims of allowing such a name change. ...

(Shell …). The emphasis in the Tax Court’s reasons on an unexpressed intention of competition is not appropriate in this case which involves a FAPI scheme that is drafted with mind-numbing detail. ...

. … Glenhuron was not managing Loblaw’s money but its own. It was an error of law for the Court to consider that Glenhuron’s money belonged to Loblaw. ...

Canada, 2020 FCA 97-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) the Cirque du Soleil’s bearing most of the $41.8M cost of a space trip for its controlling shareholder gave rise to a shareholder benefit The founder and controlling shareholder of Cirque du Soleil, had been found by the Tax Court to have received a taxable benefit under s. 15(1) (or alternatively, under s. 246(1)) equaling approximately 90% of the $41.8 million cost of sending him on a trip to the international space station (ISS) in September and October 2009, given that the cost was borne by his family holding company and then largely passed through to the top operating company (“Créations Méandres “) in the Cirque du Soleil group, but with there being a matching contribution of capital by the holding company to Créations Méandres so that independent shareholders would not bear any of the cost of the trip. ...

., 2020 FCA 125-- summary under Subsection 152(4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4) nil assessment not subject to 3-year limitation in s. 152(4) In finding that a nil assessment was valid for s. 164(1) purposes notwithstanding that it had been issued (in 2010) more than three years after the previous (2003) reassessment, Noël CJ stated (at para. 58): Subsection 152(4) gives the Minister the power to “notify in writing any person […] that no tax is payable for the year”. ...

In this regard, he stated (at para. 47, citing Wild): [I]t is now established that the modification of tax attributes, such as an increase in a taxpayer’s CDA, does not give rise to a tax benefit unless and until a capital dividend is paid out of that account to a recipient capable of benefiting from its tax-free character …. ...

The following question was posed under Rule 58: Where the Minister has at all times concluded that no partnership existed, can the Minister issue a valid Notice of Determination in respect of that purported partnership under subsection 152(1.4) …. ...

In this regard, he noted (at para. 74) the statement in Symes that “Courts will … look for objective manifestations of purpose,” and then stated (at para. 76): [S]ubsequent actions or steps taken by Keybrand or [its parent] BWS could be used to either confirm or contradict Keybrand’s stated purpose in borrowing the funds to acquire the shares of Vidabode. ...