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Such an interpretation goes against the purpose of the Act …. ...

In finding that the Customer Cash Contributions were ordinary income to the Distributors, Moshinsky J stated (at para. 165): As the Distributors’ businesses included connecting new customers to the electricity network, and as the Customer Cash Contributions were gains (in the sense that they were amounts derived) in respect of new connections, it follows that they constituted ordinary income …. ...

Before finding that the taxpayer continued to reside in Quebec for his 2009 and 2010 taxation years, Pokomàndy JCQ stated (at paras. 69-70, TaxInterpretations translation): The Court is convinced … that since 2011 this project of going to work in Ontario in order to perfect his English has become a life project that materialized with the residence transfer to this location. ...

Similarly, in the second (dismantling) case (paras. 57, 59: [T]he value of the performance of dismantling and waste disposal … must be regarded as equal to the amount that the purchaser, that is a demolition company, takes into account as a factor reducing the purchase price of the goods to be dismantled. ...

Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain, thereby generating Part III tax unless an s. 184(3) election was made. ...

Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain. ...

After noting that the description of the legal services provided had not been revealed to the ARQ on the grounds of privilege, Chalilfour JCQ stated (at paras. 133-135, TaxInterpretations translation): Not waiving professional privilege could certainly render the reversing of the presumption of validity of an assessment … more difficult. ...

He went on to state (at para. 35): …In the alternative, if the supply of the Aeroplan Supplies included multiple supplies, one of which was the separate supply of Aeroplan Miles, … the supply of the Aeroplan Miles was incidental to the supply of promotional and marketing services by Aeroplan to CIBC, such that the supply of the Aeroplan Miles is deemed by section 138 of the Act to be a part of the supply of the promotional and marketing services made by Aeroplan to CIBC. ...

In fact, the quality of the sound recording had everything to do with the quality of the physical medium …. ...

The Queen, 2019 TCC 109 (Informal Procedure)-- summary under Subparagraph 256(3)(a)(iii) Summary Under Tax Topics- Excise Tax Act- Section 256- Subsection 256(3)- Paragraph 256(3)(a)- Subparagraph 256(3)(a)(iii) substantial completion had occurred by the time of the interim occupancy certificate The taxpayer and her husband built a house, which was near Lake Huron and a 2 ½ hour drive from their Brampton rental apartment and full-time employment, doing a large portion of the work themselves on weekends beginning in 2008, with the intention to retire there. ...