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. … [A]ll that is required is that the institution be empowered to grant degrees by a relevant authority such as the province of British Columbia. … ...

. … In this case, the only possible conclusion is that the monies received by the respondent are success fees for driving and training services it provided to owners, not "prizes" within the meaning of subsection 188(2)…. In support of this conclusion, he referenced Rule 18.11 of the Rules of Standardbred Racing enacted under the Racing Commission Act 2000 (Ontario), and stated (at para. 24): [T]he Rule confirms that "drivers' and/or trainers' fees " [my emphasis] are deducted from the owners' purse money. ...

.… … The appellant is neither a lawyer nor a notary. Therefore, in this case, section 231.7 still authorized the Federal Court to make the order it did. Respecting the further submission that the order “indirectly ordered the appellant’s law firm to disclose material, contrary to the Supreme Court’s two decisions” he stated (para. 9): … The Federal Court’s order is directed only against the appellant…. ...

VI, s. 22, which exempted “A supply of a service, made by a municipality … of... installing, repairing, maintaining or interrupting the operation of a water distribution, sewerage or drainage system,” Pelletier JA first noted (at para. 39) that “no matter how one reads the sentence, it is ungrammatical and ambiguous,” but then stated (at paras. 41, 44-45): It is clear from the French version that the service supplied by the municipality is that of installing, repairing or maintaining a water distribution network or a sewer or drainage system, or interrupting the operation of such a network or system. ... The primary sense of the verb [“entrenir”] is sufficiently broad to include and, in my view, does include, the operation of a thing or a system. … As for the meaning of the verbs “to maintain” and “entretenir”, there is an overlap between the two versions, with the French verb emphasizing a meaning which is present in English, though not as the primary meaning. ...

. … 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. ...

. … 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. ...