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" More interestingly, he also found that in the absence of this Regulation, the service would have been exempt as being for the payment of insurance policy claims – notwithstanding that the Emergis service entailed the provision of taxable supplies described in para. ...

In the Tax Court below, Owen J ultimately found that the charges of Emergis to Great-West for this service were taxable under the Financial Services and Financial Institutions (GST/HST) Regulations, as they were "quintessentially administrative in nature," and also found that, in the absence of this Regulation, the service would have been exempt as being for the payment of insurance policy claims – notwithstanding that the Emergis service entailed the provision of taxable supplies described in para. ...

Canada, 2016 FCA 301-- summary under Section 32 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 32 s. 32 addresses where the prescribed information is timely filed but prescribed form not used D'Arcy J had found that the taxpayer’s late-filing (by six weeks) of Schedule 31 meant that its SR&ED credits for the year in issue were properly denied – even though the information needed to calculate the credits was in its return and on Form 661, which it had filed on a timely basis. ...

The bottom line is that the appellant engaged in RRSP stripping transactions and that is the factual basis relied upon by the Minister in issuing the reassessments …. ...

. … I recognize that we are not dealing here with a word in a federal statute which takes its meaning from provincial laws. ...

. … Any removal by the Chief Justice of a judge who is seized of a matter would also conflict with the principle that the person who decides a case must be the same person who hears the case…. ...

. … The taxable transactions in this appeal occurred when the appellant exercised his stock options…. ...

., – who also thereupon became member of the Appellant, along with the Canadian and U.S. ...

He also found that providing the ½ deduction under s. 110(1)(d) to the taxpayers accorded with the broader context of the stock option rules. ...

University Hospitals Board, 2006 ABCA 101, 384 A.R. 23, the majority of the Alberta Court of Appeal stated that: … Where a settlement offer does not contain an element of compromise, the court may nevertheless consider it to have been reasonable in the circumstances and exercise its discretion to award enhanced costs. ...