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. … 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 ….) ...

. … Deeming provisions create legal fictions. They assume things to exist even when they do not in reality—like, for example, the supply of a home that is not yet constructed. … Other elements found in the text, context and purpose of the statute support the interpretation that supply means the signing of an agreement of purchase and sale and not a transfer of beneficial ownership. ...

. … [O]n my interpretation a taxpayer in response to a query need only produce the agreement of purchase and sale to show the legal acquirer of the complex and easily obtained personal documents, such as utility bills, other standard invoices, and drivers’ licences to show who is personally residing in the complex. On my colleague’s view … [s]uddenly a straightforward verification exercise morphs into a sprawling examination for discovery. ...

Webb JA found that the s. 96(1.1) distribution did not satisfy the applicable requirement in s. 14 of the CPP Act that it be “his income for the year from all businesses … carried on by him” (he instead was retired). He stated (at para. 30): The deeming rule in subsection 96(1.1) … only provides that Mr. ...

Webb JA found that the s. 96(1.1) distribution did not satisfy the applicable requirement in s. 14 of the CPP Act that it be “his income for the year from all businesses … carried on by him” (he instead was retired). ... As a result he was not carrying on a business in common with other partners of Deloitte & Touche LLP at any time in 2008 for the purposes of the CPP. ...

. … In this case, the Tax Court found that the relevant documents contained much more than financial information, as was the case in Boulangerie St-Augustin …. ...

. … [I]n order to have a “liquidated money demand, recoverable by action” one must know the identity of the debtor and the amount owed …. ...

Canada, 2019 FCA 5-- summary under Subsection 169(2.2) Summary Under Tax Topics- Income Tax Act- Section 169- Subsection 169(2.2) taxpayers had given valid waivers given full knowledge of the rights which they had unequivocably waived Rossiter CJ had found that the taxpayers had given valid waivers of their right to appeal: even though the waiver letter drafted by CRA was “poorly worded … if read in its entirety … there is a sufficient and adequate explanation in the letter [such] that a person would have full knowledge of the rights being waived.” ...