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Before setting this order aside and directing that the Certificates of Appointmentbe be issued, Marrocco ACJ stated (at paras 34-35) that a will (which “is an instrument by which a person disposes of property upon death”) may “contain a trust, but this is not a requirement for a valid will” and quoted with approval (at para. 37) the statement in Williams on Wills that “Although the title to the assets vests in the personal representative … the property comprised in residue is not held in trust for the beneficiary under the will so as to invest any equitable interest in him.” ...

After confirming the decision of the Minister to revoke the registration of the Foundation under s. 168(1)(e) on the grounds of essentially no records substantiating the consulting fees (and in finding that the decision of the Minster to revoke under s. 168(1)(b) on the grounds that the consulting fees had not been established to satisfy the requirement for the Foundation to devote all of its resources either to charitable activities or as gifts to qualified donees, Woods JA stated (at paras. 53, 57): … The Appeals Directorate noted that most of the funds received and disbursed by the Foundation were to registered charities in which …[Mr. ...

Such an interpretation goes against the purpose of the Act …. ...

In finding that the Customer Cash Contributions were ordinary income to the Distributors, Moshinsky J stated (at para. 165): As the Distributors’ businesses included connecting new customers to the electricity network, and as the Customer Cash Contributions were gains (in the sense that they were amounts derived) in respect of new connections, it follows that they constituted ordinary income …. ...

Before finding that the taxpayer continued to reside in Quebec for his 2009 and 2010 taxation years, Pokomàndy JCQ stated (at paras. 69-70, TaxInterpretations translation): The Court is convinced … that since 2011 this project of going to work in Ontario in order to perfect his English has become a life project that materialized with the residence transfer to this location. ...

Similarly, in the second (dismantling) case (paras. 57, 59: [T]he value of the performance of dismantling and waste disposal … must be regarded as equal to the amount that the purchaser, that is a demolition company, takes into account as a factor reducing the purchase price of the goods to be dismantled. ...

Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain, thereby generating Part III tax unless an s. 184(3) election was made. ...

Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain. ...

After noting that the description of the legal services provided had not been revealed to the ARQ on the grounds of privilege, Chalilfour JCQ stated (at paras. 133-135, TaxInterpretations translation): Not waiving professional privilege could certainly render the reversing of the presumption of validity of an assessment … more difficult. ...

He went on to state (at para. 35): …In the alternative, if the supply of the Aeroplan Supplies included multiple supplies, one of which was the separate supply of Aeroplan Miles, … the supply of the Aeroplan Miles was incidental to the supply of promotional and marketing services by Aeroplan to CIBC, such that the supply of the Aeroplan Miles is deemed by section 138 of the Act to be a part of the supply of the promotional and marketing services made by Aeroplan to CIBC. ...