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. … [A] GST registrant should be entitled to determine its input tax credits on the basis of information in its possession without having to resort to hiring expensive third parties, such as valuators or, as I will discuss, engineers to measure spaces on its ships or experts to try to determine what percentage of fuel is consumed to propel a ship and what percentage is consumed to produce electricity, heat or hot water. … He also noted (at para. 126) that the taxpayer’s method appeared to be better than the output-based method used by it in earlier reporting periods and accepted by CRA. ...

This amounts to wilful blindness …. She briefly found in the alternative that he had been grossly negligent, stating (at para. 83): Failure to review a return at all is suffic[ient] to find that any false statements in the Return are made in circumstances amounting to gross negligence …. ...

However, that is all it does …. There is nothing in the wording of subsection 13(31) that creates the fiction of the Limited Partnership having a year-end prior to February 1, 2005 …. ...

In concluding that Gorgis had satisfied s. 254(2)(g)(i) through being the first occupant of the home “as a place of residence,” Cook J found that: Gorgis’ staying there two to four nights a week was consistent with it being a place of residence; Although he only moved in with “six pieces of luggage and a limited assortment of furniture … there [was] no indication that he had significant personal belongings elsewhere” (para. 26); and “His use of the Property was more than transitory – he was the sole occupant of the Property for one year and he still owns it and has use of the basement” (para. 27). ...

The King, 2024 TCC 130-- summary under Section 5 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 5 a Canadian agent’s services were not zero-rated since they were partly performed in Canada The appellant (MELP) was found to be performing its services to Canadian patients who underwent bariatric surgery at the surgical unit in Mexico of a Mexican company (“LIMARP”) as agent for LIMARP given that their conduct- including MELP being subject to control over health-related matters by LIMARP, and being implicitly authorized to deal with the patients before and after the operation, and MELP quite regularly remitting the fees that it collected from the Canadian patients, other than the 50% portion thereof retained by it for its services, to LIMARP – implied an agency arrangement. Accordingly, MELP was not subject to GST/HST on the ½ portion of the patient fees that it collected as agent for LIMARP. ...

. … [T]he phrase “return of premium” may be an accurate description of the maximum amount received by the Appellant upon the expiry of the term but it is misleading for the following reason. ... What the insurer paid as a benefit upon the expiry of the term was not, in a business sense or in an income tax sense, any part of the premiums for life insurance. … It was part of the insurer’s earnings. ...

. … The use of specific examples after a general term in legislation does not restrict the meaning of the general term to cases similar to the specific examples. ... Katsikonouris, [1990] 2 S.C.R. 1029 …. See summaries under Sched. V, Pt. ...

Richards was not a “particular individual”, stating (at paras. 16, 17 & 19): [S. 254(2)(a)] requires the builder to make a supply by sale to Ms. Richards in order for her to be a particular individual. … Ms. Richards not only believed that she had acquired no interest in the subject unit, but…at law, she had no beneficial interest… [T]he only supply made by the builder was the supply made pursuant to the original agreement. ...

., “more than 50% of their value” (para. 120)) from portfolio investments, Lamarre ACJ stated (at paras. 101-103): [T]he ordinary commercial meaning of portfolio investment in the international investment context is an investment in which the investor … is not able to exercise significant control or influence over the property invested in.... [T]he definition suggests thresholds ranging from 10% to 25% ownership … [although] a small group of well-organized investors could have a controlling interest while having less than 10% ownership…. ...

. … The legislator, in enacting subsection 69(11) and 110.6(7) of the Act, had no intention of neutralizing the effect of subsection 74.2(1) in circumstances such as these. … In the context of the attribution rules, the purpose of the [s. 73] election is to permit a taxpayer to defer or not the realization of a gain, and not to permit a taxpayer to avoid attribution. ...