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. … Second, the legislator was careful to add "including guarantees or rights of set-off /y compris les garanties et droits de compensation". … The word "guarantees" must be taken in its broad sense, which includes suretyship. ... As for "rights of set-off /droits de compensation", the AGC is right to point out that these are personal rights. … Third, the [Finance] Explanatory Notes to the Regulations support this interpretation. … Gagné JCA went on to agree (at para. 44) with the essentially undisputed point that all the payments of interest (as well as principal) on the loan after the default date (July 15, 2014) reduced the PSI of the Caisse. ...

Ontario (Finance), 2007 CanLII 4786 (ON SC)-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) “use” and “consumption” have separate but similar meanings S. 2(1) of the Retail Sales Tax Act (Ont.) imposed tax on “every purchaser of tangible personal property … in respect of the consumption and use thereof….” ... Low J stated (at paras. 12-13, 15): [O]n the plain and ordinary meaning of the word “use”, … the appellant is the user of repair parts. The appellant is in the warranty business. … How does the appellant go about its business? ...

The Court dismissed the appeal, stating (at paras 10 and 16-17): [W]aiver form T2029 “bears the insignia of the … [Canada Revenue Agency (“CRA”)] and the Government of Canada and … is regularly used by the CRA.” ... Finally, we agree … that advice …from government agencies under freedom of information type legislation and a statement in the respondent’s motion factum did not amount to calling into question form T2029 as a prescribed form. ...

Vadnais' report, which contains a multitude of photographs, taken on August 5, 2015 … clearly indicates that 35 out of 88 units were not ready for rental. … The report also indicates that a significant portion of the underground parking garage was used to store materials and equipment such as, for example, bathroom vanities, kitchen countertops and equipment, etc. … Although the rule of thumb of 90% of the costs incurred may be appropriate in the vast majority of cases, for formulating, without further effort, an equivalence between a specific percentage of costs incurred and the concept of a "substantially completed" building, this does not seem justified under these circumstances. ...

Other than this table, the appellant did not file supporting documents regarding the percentages set out therein, be they time sheets, SR&ED progress reports, correspondence, minutes of meetings, internal notes or emails related to these tasks, nor did it … call any of the employees from these two groups as witnesses to support these percentages …. The Court went on to confirm the finding in the Court of Quebec find that the taxpayer had not “demolished” the basis for the assessments by demonstrating, “on a prima facie basis, that the respondent’s premise — i.e., that the appellant had not shown that the reported portions of each employee’s salary could reasonably be attributed to the prosecution of SR&ED — was false” (para. 25). ...

In dismissing the appeal, the Court stated (at paras 13, 20, TaxInterpretations translation): … The trial judge and the respondent are correct in stating that "[a] person who avoids the payment of a tax imposed under the Act, necessarily avoids compliance with the Act." The provision creates a single offence- tax evasion- the meaning and scope of which would be even clearer by rephrasing the wording as follows: "has voluntarily, in any way, evaded or attempted to evade the payment of a tax imposed under that Act, or otherwise evaded or attempted to evade compliance with this Act ". The appellant criticizes the judge for creating a problem of duplication that does not exist. … [T]he tax evaded underlying the counts in issue was not due by the appellant. ...

. … [T]he contracts provided for services to be provided as consideration for the payments. … The argument put forward... that they are “nothings” for Canadian tax purposes because they are merely reputational payments arising in a non-business circumstance may ultimately be upheld by the Tax Court, but it is not so clear at this stage as to render the CRA’s position unreasonable. ...

HMRC’s statutory ability to open up such return with a “discovery assessment” depended inter alia on establishing that, under s. 29(4) of the Taxes Management Act 1970, the insufficiency of the initial assessment of the year “was brought about carelessly or deliberately by the taxpayer or a person acting on his behalf,” with s. 118(7) further providing that “in this Act references to … a situation brought about deliberately by a person include … a situation that arises as a result of a deliberate inaccuracy in a document given to Her Majesty’s Revenue and Customs by or on behalf of that person.” ... Furthermore, the Revenue-approved online tax return form used by Mr Tooth and his advisors contained numerous “white spaces” … within which the taxpayer is invited to add information using his own words and phrases, so as to ensure that the declaration [was accurate]. ...

. … Had the Legislature intended the BC GAAR to cover misuse or abuse of provisions beyond the BC Act and its regulations, such as the federal Act, it could easily have adopted the explicit language in subsection (c) [the equivalent of ITA s. 245(3), which referred to the reduction, avoidance or deferral of tax under the B.C. ... How the provinces tax that income, if at all, is beyond the purpose, object and spirit of the Allocation Rules. … I note the… comment in Copthorne …that: … in some cases the underlying rationale of a provision would be no broader than the text itself. … [T]he underlying rationale of providing a mechanism of allocation is fully explained by the formula it provides, choosing, as it did, to use gross revenues and salaries and wages as the factors. ...

In also rejecting the single property argument, Fournier JCQ stated (at paras 551-552): [T]he assets acquired under the … franchise agreement must be considered separately for tax shelter determination purposes because they have different tax characteristics. The software suite is a Class 12 property while the membership right is an eligible capital property with different rates of depreciation. … The definition of tax shelter contained in TA section 1079.1 … militates in favour of an individual analysis of the property in question in order to determine whether or not it qualifies as a tax shelter. ...