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. … In other words, any action taken to obtain a tax benefit would be an avoidance transaction and there would never be an occasion to determine the primary purpose of a transaction. … The words of the Act require consideration of a transaction in its entirety and it is not open to the Crown artificially to split off various aspects of it in order to create an avoidance transaction. ...

In the course of upholding the finding that this was a misrepresentation attributable to neglect, thus allowing the taxpayer to be assessed beyond the normal reassessment period (see summary under s. 152(4)(a)(i)), Webb JA disagreed with the trial judge's statement that "if the Minister establishes that there is a right to reassess after the expiration of the normal period, the onus will then shift to the taxpayer" to show that the failure to include the amount in the return was not due to a misrepresentation attributable to neglect, carelessness or wilful default, stating (at paras. 24-25): [T]he onus is on the Minister to establish, on a balance of probabilities, that the taxpayer or the person filing the return … has made a misrepresentation; and … such misrepresentation is attributable to neglect, carelessness, or willful default.... ...

In allowing the taxpayer’s appeal from the disallowance of expenses claimed under s. 8(1)(f), Rennie J.A. stated (at para. 6): [R]egarding the contract objectively, it was an implicit or implied term that the employee would be required to incur certain costs in order to earn the commissions contemplated by the contract; see Sattva [2014 SCC 53, [2014] 2 S.C.R. 633] at para 49 [“in contractual interpretation, the goal of the exercise is to ascertain the objective intent of the parties — a fact-specific goal — through the application of legal principles of interpretation”]. ...

. … [A]ll that is required is that the institution be empowered to grant degrees by a relevant authority such as the province of British Columbia. … ...

. … In this case, the only possible conclusion is that the monies received by the respondent are success fees for driving and training services it provided to owners, not "prizes" within the meaning of subsection 188(2)…. In support of this conclusion, he referenced Rule 18.11 of the Rules of Standardbred Racing enacted under the Racing Commission Act 2000 (Ontario), and stated (at para. 24): [T]he Rule confirms that "drivers' and/or trainers' fees " [my emphasis] are deducted from the owners' purse money. ...

.… … The appellant is neither a lawyer nor a notary. Therefore, in this case, section 231.7 still authorized the Federal Court to make the order it did. Respecting the further submission that the order “indirectly ordered the appellant’s law firm to disclose material, contrary to the Supreme Court’s two decisions” he stated (para. 9): … The Federal Court’s order is directed only against the appellant…. ...

VI, s. 22, which exempted “A supply of a service, made by a municipality … of... installing, repairing, maintaining or interrupting the operation of a water distribution, sewerage or drainage system,” Pelletier JA first noted (at para. 39) that “no matter how one reads the sentence, it is ungrammatical and ambiguous,” but then stated (at paras. 41, 44-45): It is clear from the French version that the service supplied by the municipality is that of installing, repairing or maintaining a water distribution network or a sewer or drainage system, or interrupting the operation of such a network or system. ... The primary sense of the verb [“entrenir”] is sufficiently broad to include and, in my view, does include, the operation of a thing or a system. … As for the meaning of the verbs “to maintain” and “entretenir”, there is an overlap between the two versions, with the French verb emphasizing a meaning which is present in English, though not as the primary meaning. ...

. … 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. ...

The Crown relies on the distinction drawn in this publication between remedial amendments and clarifying amendments and emphasizes the assertion that in this case the amendments “clarify” the prior law (… Economic Action Plan 2012, pp. 414-415 ….) ...