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In commenting on the third ground, he stated (at paras. 21, 23): [T]he Assistant Commissioner … stated that “the legislative intent [is] that only purchasers who are not consumers can take possession of goods in Canada for export on a zero-rated basis.” ... He also implicitly acknowledged the general intent noted in Montecristo … that GST/HST should be limited to consumption within Canada. The next sentence of the Assistant Commissioner’s analysis is equally reasonable in view of the more particular intent reflected in the detailed conditions for zero-rating: “Goods purchased by non-resident consumers are only intended to be zero-rated if they are shipped to a destination outside Canada, or they are sent by mail or courier to an address outside Canada.” … The Assistant Commissioner concluded reasonably that the predicament in which Escape Trailer found itself (being liable for HST amounts that were not collected from customers) was caused not by any unintended results of the legislation, but rather by its failure to comply with any of the detailed conditions for zero-rating. ...

In confirming that CRA had not acted unreasonably in declining to recommend a remission order under s. 23(2) of the Financial Administration Act, Locke JA noted that CRA had “implicitly acknowledged the general intent noted in Montecristo … that GST/HST should be limited to consumption within Canada,” but had reasonably considered that “Goods purchased by non-resident consumers are only intended to be zero-rated if they are shipped to a destination outside Canada, or they are sent by mail or courier to an address outside Canada,” and further stated (at para. 23): The Assistant Commissioner concluded reasonably that the predicament in which Escape Trailer found itself … was caused not by any unintended results of the legislation, but rather by its failure to comply with any of the detailed conditions for zero-rating. ...

In confirming the decision below that the Minister was bound by the settlement agreement respecting the March 7, 2007 TY, Woods JA stated (at paras 31, 32, 33, and 35): [T]he principles from Galway do not provide the relief that the Crown seeks …. ... Third, the Crown does not suggest that the defect within the settlement agreement is self-evident to the Court as it was in Galway. … The general rule is that parties should be bound by the agreements that they make. ...

Deyab for failing to call his accountant or bookkeeper, or presenting a properly completed shareholders’ loan account reconciliation” (para. 48) – hence, there had been a misrepresentation. Before so finding, he quoted (at para. 46) the statements in Sopinka, Lederman & Bryant: The Law of Evidence in Canada that: §6.471 In civil cases, an unfavourable inference can be drawn when, in the absence of an explanation, a party litigant does not testify, or fails to provide affidavit evidence on an application, or fails to call a witness who would have knowledge of the facts and would be assumed to be willing to assist that party. ...

Monaghan JA found that the Tax Court had made no reversible error and rejected, among other Carvest submissions, that “because the Tax Court characterized the property to be valued as condominium units, rather than leased apartments, it considered itself bound to use the direct comparison method and the individual condominium resale market,” noting that “the Tax Court understood the units were rented but also qualified as “residential condominium units” for purposes of the Excise Tax Act” (para. 26) and stated further (at para. 32) that she was “ satisfied that the Tax Court chose the direct comparison valuation method because it decided it was the appropriate method in this case for the reasons it explained….” She further stated (at para. 35): The appellant … suggests that the proper approach is to first determine the value of the property and then decide which part of section 191 applies—subsection 191(1) or 191(3)…. ...

Canada, 2000 DTC 6250 (FCA)-- summary under Personality Summary Under Tax Topics- General Concepts- Personality Rothstein J.A. applied (at p. 6256) the determination in Pioneer Laundry & Dry Cleaners Ltd. v. ...

Canada, 2000 DTC 6250 (FCA)-- summary under Separate Existence Summary Under Tax Topics- General Concepts- Separate Existence corporate veil not pierced Rothstein J.A. applied (at p. 6256) the determination in Pioneer Laundry & Dry Cleaners Ltd. v. ...

London & West Riding Investments Ltd. case stated (at p. 5114): "In other words, the elements of a sham require that the parties to a transaction together have deliberately set out to misrepresent the actual state of affairs to a third party.... ...

London & West Riding Investments Ltd. case stated (at p. 5114): "In other words, the elements of a sham require that the parties to a transaction together have deliberately set out to misrepresent the actual state of affairs to a third party.... ...

HER MAJESTY THE QUEEN, 2020 FCA 195-- summary under French and English Version Summary Under Tax Topics- Statutory Interpretation- French and English Version "peut" (may) in French version accorded with a sense of the English version's "shall" Noël CJ effectively found that the word “peut” (may) in the French version of s. 118.1(11) meant the same thing as the word “shall” in the English version, stating in this regard (at para. 53): [T]he use of the word “peut” in the French version illustrates how “an official who is permitted to do a thing may, in addition, be obliged to do it” (Ruth Sullivan, Sullivan on the Construction of Statutes …). ...