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. … …. Section 88, as drafted at the time, did not require the Appellant to look at the nature of the assets of the First Level LPs to determine the amount by which it could bump its interest in the limited partnerships. ...

The benefit is …. 10% of construction costs of $259,293 or, $25,929. This is clearly an advantage not available to regular customers and only available to Mr. ... However, in finding that the Jaques did not for the most part receive shareholder benefits in connection with the Furnishings, he stated (at para. 38): … Park Haven's sole purpose in acquiring most of the Furnishings was not to bestow any benefit on the shareholders, but to furnish a show home so as to enhance the saleability of custom homes in the area. ...

. … The [wife and children] acquired the shares from the Appellant for a purchase price of $0.01 per share and immediately thereafter sold them for a cash purchase price of $8,645 per share. ... If the minimum EBITDA Target set out in the SPA was not met, the Appellant’s wife and daughters were still entitled to retain the full cash purchase price that they received. … [T]he price agreed to by the Appellant’s wife and two daughters on the one hand, and Dental Corporation on the other, satisfies the definition of the term “fair market value”, which is understood to mean “the highest price an asset might reasonably be expected to bring if sold by the owner in the normal method... in a market not exposed to any undue stresses and composed of willing buyers and sellers dealing at arm’s length and under no compulsion to buy or sell”. ...

Hogan J stated (at para 25): … In Aridi, I held that an accountant’s neglect or carelessness in preparing a tax return is not sufficient in and of itself to allow the Minister to reassess beyond the Normal Reassessment Period. ... Hogan J dismissed the appeal, finding (at para 31): When a taxpayer hires an accountant to prepare his tax return and is aware that tax planning involving a deferral strategy … is being used to secure a tax advantage for the taxpayer’s benefit, a minimum degree of attention to or oversight over the accountant’s work must be exercised by the taxpayer. ...

The Queen, 2018 TCC 48-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation corp qualified as SBC where only business activity was unsuccessful efforts to sell its stock of equipment The market for the business of a corporation (“Radio Progressive “) of the taxpayer (Mr. ... Hébert from his disposition of its shares in August 2011 qualified as a business investment loss, Ouimet J stated (at paras. 19-22, TaxInterpretation translation): [19] In this case, the Court is of the view that Radio Progressive was carrying on an active business during the 12 months preceding its dissolution, namely in the 2010 and 2011 taxation years, despite the fact that its activities were minimal. … [20] Essentially, based on the evidence, Radio Progressive remained active in the years prior to its dissolution only in order to dispose of its stock of unsold radio communication equipment and parts. ...

Russell J further found that the taxpayer was not a de facto director, stating (at paras 38, 40): Jurisprudence reflects that the concept of de facto director should be limited to persons who hold themselves out as directors …. ... …[S]he engaged in no acts of management … let alone any actions specific to a director. ...

. … Mr. Davis’ residency in Canada before May 9, 2013 was preparatory to disengaging from the U.S. and permanently ceasing to be a resident after May 9, 2013. ... Davis … habitually lived in the U.S. based upon frequentcy, duration and regularity. ...

He went on to state (at paras. 32, 35): This case demonstrates that there is clearly a gap in section 160 … [but s]imply amending section 160 to cause it to cover the non-arm’s length provision of services may have undesired consequences. … If a tax debtor spent all of his or her free time caring for his or her aging parents, would the Minister assess the parents for the fair market value of that care? ...

. … [T]he definition of “legal representative of a taxpayer” found in subsection 248(1) does not apply to determine who is a “person” under the Act. … …Mrs. ...

Toca, 2018 BCCA 191 …. Although there is no evidence in this case that IPG provided any consideration to Houweling in return for his agreement to wait for payment of the loan, there is nothing to suggest that IPG exerted any economic pressure on Houweling to obtain the variation in the loan agreement and that there are no public policy reasons that would render the agreement unenforceable. … As a result, there was no amount owing by IPG to Houweling during the year that followed the issuance of the RTP and therefore no amount owing by IPG under the ITA as a result of its failure to make any payment to the Minister pursuant to the RTP. ...