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He testified that “he never developed a strong sense of belonging to Quebec” and that “his best friend … lived in Ontario” (para. 43). ...

In the case of a lease, there can be no assignment of the lease to the limited partnership – it must be assigned to the general partner. ...

A few days before the hearing of the appeal by his estate, its notice of appeal was amended to allege inter alia that Gagné had never been a director (given that the proper corporate procedures had not been followed for his appointment, including his consenting to such appointment. and there being an absence of any resolution appointing him) – an argument never made by Gagné. ...

.”), during the taxation years at issue, suspended the operation of its golf course to backfill two artificial lakes in its driving range and to replace its clubhouse and garage – as well as to partially construct (but never complete) a mini golf course. ...

The only revenues of Galaxia were commissions calculated and collected as a percentage of the billings received by SM from the contracts generated by Galaxia – so that its revenues were highly variable (e.g., $179,991 in 2009 and $760,000 in 2010). ...

In addition, there was “no evidence that the interests of the Mohawks of Kahnawà:ke have been taken seriously in the elaboration of the Excise Act, 2001 ” (para. 1605) so that the “the Crown did not discharge its duties to consult- and even less to accommodate” (para. 1622). ...

. … [T]he work done in 2009, 2010 and 2011 on the building was in the nature of repairs. ...

The jurisprudence clearly demonstrates that ignorance of the provisions of the ITA and of the obligations of taxpayers in managing their TFSA accounts, or the receipt of bad advice, do not constitute a "reasonable error" within the meaning of subsection 207.06(1), justifying the exercise of the Minister's discretion …. ...

The board of GEFI Inc [a subsidiary of GEFI], as the LP's general partner, did not make strategic decisions and in fact had "very little involvement" …. ...

., both before and after the emigration time) – hence, s. 128.1(4) had no application and the trust avoided capital gains tax on shares held by it with an accrued gain. ...