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. … Accordingly, Callidus was liable to the Crown under s. 222(3) for its pre-bankruptcy breach of the s. 222(1) deemed trust. ...

She concluded (at paras 50 and 51) that as “Menova did not put funds at the disposal of North Shore when it issued the credit memos … section 232 does not apply to the transactions at issue as HST was not credited to North Shore.” ...

. … [T]he CRA’s power to issue requirements under section 231.2 of the ITA to obtain information or documents that will be used for the administrative purpose of reassessing a taxpayer is not suspended by the commencement of an investigation. ...

Canada, 2018 FCA 110-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) s. 152(4.2) inapplicable where reassessment, albeit in response to refund request, increased taxpayer’s liability The taxpayer retired as a partner from Deloitte & Touche LLP in 2007. ...

. … The situation is one in which the mistake should be corrected by a reassessment rather than by finding the assessment to be void. ...

. … [I]t is because interest is, by its nature, symmetrical that the Judge was correct in interpreting subsection 16(1) in the way that he did. ...

In finding that the Tax Court had not committed a palpable and overriding error in this regard Webb JA stated (at para. 43): If the transactions are viewed as only the permits being transferred from Kinderock to the limited partnership and then by the limited partnership to Devonian, … the permits would not be used in an active business being carried on by the limited partnership as they would be transferred immediately upon being received by the limited partnership. ...

However, although in form Veracel was the larger corporation, essentially all its assets were the subscription-receipt cash proceeds – and “There was no scenario under which Veracel would have been allowed to retain the money…” (para. 53). ...

This general rule has only one exception, which is the case in which the question before the court has an inevitable answer …. ...

Gleason JA also rejected a submission that the Tax Court had focused insufficiently on whether there had been a corporate intent to impoverish the corporations, stating (at para. 44) that “this Court … [has] found that a shareholder benefit was conferred without any determination having been made as to the corporation’s intent” and (at para. 45) “even if intent to impoverish the corporation were required, such intent cannot be equated with a controlling shareholder’s subjective intent and most especially not with an intent that was formulated [as in the case here] after the corporate expenditure was engaged”. ...