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The jurisprudence clearly demonstrates that ignorance of the provisions of the ITA and of the obligations of taxpayers in managing their TFSA accounts, or the receipt of bad advice, do not constitute a "reasonable error" within the meaning of subsection 207.06(1), justifying the exercise of the Minister's discretion …. ...

The board of GEFI Inc [a subsidiary of GEFI], as the LP's general partner, did not make strategic decisions and in fact had "very little involvement" …. ...

., both before and after the emigration time) – hence, s. 128.1(4) had no application and the trust avoided capital gains tax on shares held by it with an accrued gain. ...

. … [Furthermore] there was a long period of inactivity, the evidence clearly illustrating that the [pre-AoC] company was at a standstill for quite some time. ...

. … [Furthermore] there was a long period of inactivity, the evidence clearly illustrating that the Pierres Gémo Inc. company was at a standstill for quite some time. ...

Bowie J stated (at para. 13): [O]nly an insurance company licensed to do so may sell insurance, and only a provincial government may sell motor vehicle licences… Vanex Truck Service was distinguished (at para. 17) on the basis that: [W]hat Vanex supplied to the drivers was the right to drive their vehicles with the benefit of licences and insurance for which it had paid … [and] the Appellant does not appear to have advanced an argument based on agency in that case. ...

Attorney General of Canada, 2024 ONSC 1955-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) trust allocation resolution rectified to set out specific amounts After a discretionary family trust realized a capital gain from a share sale, the sole trustee passed a resolution in that year providing that “[t]he income of the Trust be allocated to the [three stated] Beneficiaries of the Trust payable by way of demand Promissory Note in such amounts to be determined when the income of the Trust is ascertained ….” ...

Before going on to find that s. 30.5 of the Tax Administration Act (Quebec) required the ARQ to take such refund claims into account when assessing the taxpayer, Hamilton JCA stated, regarding the QSTA equivalent of ETA s. 225(1) – B(a) and (b) (paras. 27-28, TaxInterpretations translation): First, Article 428 of the QSTA distinguishes between refunds and deductions. ...

To this end, the trustees entered into an agreement with two beneficiaries, who were sons of the father, under which the trustees undertook to exercise their powers according to the instructions given by the sons and to not make decisions without their prior consent – and to resign in the event of disagreement with the sons' instructions. ...

Before concluding (at para. 382) that “the taxpayer has established that the prices that CMPL was paid by GIAG for the copper concentrate it supplied to GIAG under the February 2007 Agreement were within an arm’s length range” (and before quoting, at para. 325, with approval the statement in Cameco that “The traditional transfer pricing rules must not be used to recast the arrangements actually made among the participants,”) Davies J stated (at paras. 181, 313-314): In the present case, the relevant mine producer for the purposes of the hypothetical [arm’s length] agreement is a mine producer with all the characteristics of CMPL, which include … that it had no need for a logistics or marketing division because it sold the whole of its production for the life of the mine to a buyer with GIAG’s characteristics, namely a trader with a substantial marketing team which purchased the whole of the mine’s production for the life of the mine. … The taxpayer argued that the Commissioner’s approach, rather than pricing the copper concentrate as sold under the actual agreement that was in place between the related parties, required the Court to engage in a speculative task of re-imagining all of the terms of the contract to which independent parties might be expected to have agreed, including by: converting a contract that applied for the whole of the 2007 to 2009 period, with no facility for annual renegotiation, into one that was renegotiated annually; replacing the price sharing basis of the actual agreement with a TCRC provision set by reference to the Japanese benchmark; and replacing the quotational period optionality with back pricing under the actual agreement with a different quotational period provision. ...