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Keeping establishes that the Tax Court’s role is not to evaluate a taxpayer’s business acumen, a principle the Tax Court respected …. ...

Goyette JA found that the Tax Court had failed to recognize that the redemption amounts, although paid in the course of PC Bank’s exempt financial services business, were also paid in the course of its commercial activity of “driving customers to Loblaws” – and that it did not matter that PC Bank was incurring a loss on this commercial activity because a commercial activity of a corporation was not required to have a reasonable expectation of profit. ...

Canada, 2024 FCA 192-- summary under Certainty Summary Under Tax Topics- Statutory Interpretation- Certainty Parliament seeks certainty, predictability and fairness In rejecting a submission of the taxpayer that s. 161(7)(b)(iv) was inapplicable to the computation of interest in the situation where its request to carryback a loss to an earlier year was in response to a proposed audit adjustment for the earlier year rather than the situation of a carryback request not being prompted by an unforeseeable adjustment, Woods JA found that, given that “Parliament seeks certainty, predictability and fairness in tax legislation … [i]f Parliament did not intend to impose interest when a loss carryback is claimed as a result of an audit adjustment, it is likely that Parliament would have provided for this with explicit language” (para. 39). ...

In rejecting a submission that this represented a harsh result, Woods J noted that the effect reversed in the following year – and in any event "it is well established that this Court cannot grant relief on grounds only that the result is harsh: Lans v The Queen, 2011 FCA 290. ...

Holdings …. ...

In his dissenting reasons, Marceau J.A. stated (at p. 6628) that a finding of no reasonable expectation of profit " necessarily affects all expenses and not only, as the Minister's assessments would have it, those in excess of the fees earned". ...

In his dissenting reasons, Marceau J.A. stated (at p. 6628) that a finding of no reasonable expectation of profit " necessarily affects all expenses and not only, as the Minister's assessments would have it, those in excess of the fees earned". ...

In contrast with the situation in the United Kingdom, "neither the Minister of National Revenue nor his employees have any discretion whatever in the way in which they must apply the Income Tax Act " (p. 5317). ...

. … What was being done throughout the definition of “farming” was the adoption of short “tags” to indicate different types of operations. ...

. … It is therefore apparent that the purpose of the subsidy is unequivocal and that the link with the supply in question is equally unequivocal; the service must be provided, failing which the subsidy may be cancelled. ...