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Canada, 2021 FCA 182-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose essential certainty that a film would be resold under an “option” before it generated any revenue established that s. 18(1)(a) not satisfied Hogan J had found that a tax shelter partnership, which had funded the prints and advertising expenses for films that it had purchased from Twentieth Century Fox, had not incurred such expenses for an income-producing purpose because there was no real prospect that Fox would not exercise its “options” to repurchase the films – and thus no real prospect that the films would generate revenue to the partnership. ...

A court should give significant consideration to amendments which further the ability of the trial court to determine the questions in controversy …. ...

In finding that it was an EBP, he cited (at para. 29) Oldman for the proposition that “[o]rdinarily … an Act of Parliament must prevail over inconsistent or conflicting subordinate legislation,” and then stated (at para. 30): In this case, it is not possible to reconcile the two provisions as they apply to the D2L Employee Trust. ...

The judge found that the affidavit contained no express statement to that effect nor did it implicitly establish that requirement …. ...

The reliability criteria is satisfied only if the contents of the document sought to be admitted into evidence are trustworthy by reason of the way the document came into existence and the circumstances allow the judge to assess its reliability …. ...

. … [G]iven that the appellant did not acquire the services, it could not provide them as in kind benefits. ...

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[C]onsistent with Nash … the first step is to identify the property to be valued [i.e., each “condo” unit]. ...

In rejecting this submission, Gleason JA stated (at paras. 15, 24): On its plain meaning, a deeming provision does not constitute an “election” or “appointment” …. ...

. … It is highly unlikely that Parliament would explicitly provide that any supply of an orthodontic appliance is zero-rated if the intention is that the supply is restricted to the wholesale level. ...