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. … [T]his Court has held that even when penalties were assessed as a result of accountant error, the Minister is not required to exercise her discretion …. ...

This cannot be said of the Oldco Note …. The consideration for the surrender or forgiveness of the valuable Newco Note was the surrender or forgiveness of the Oldco Note with nominal value. ... It is precisely “at the time” of transfer that the consideration proffered “at such time” was deficient …. ...

In finding that s. 261(2)(b) precluded a right to rebates, and that there had been a failure to file notices of objection to the initial assessments of the self-assessed tax, Woods JA stated (at paras. 79, 81): … [A]ssessments were made of the particular tax that was paid by the Funds. ... The provision is not limited to assessments issued to persons who paid the tax. … [T]here was a remittance of tax by the Manager on behalf of the Funds. ...

The respondent argues that … the buyers could not affect the legal position of Lohas, since the principal could not have contracted with Apple (para. 111).... … [A]ssuming the buyers purchases were in violation of Apple policy[,] at most this made the purchase contracts voidable and not void. ...

In finding that the taxpayer’s floral-arranging activity did not constitute “farming,” Gibbens JCQ noted the element of artistry in this activity, observed that although the flowers would still grow while being kept in the greenhouses, this was not the predominant element in a process that entailed the creation of something new, and stated (at para. 55, TaxInterpretations translation) that the activity: also entailed an aspect of processing, as the purchased plants … were subject to a series of standard procedures: they were arranged with each other and with other materials and placed in pots in a particular manner according to a precise model. The plants and other material underwent a change in form and appearance to become the final product – the arrangements sold to the customers. ...

Favel J found that the taxpayer had implicitly requested the Minister for an extension pursuant to s. 166.1 of the time for objecting, stating (at para. 50): Notices of Objection filed after the 90 day delay for objecting, but within the extension of time delay, have been interpreted as implicit applications to extend time …. ... Rather, the Minister remained passive for two years …. The Minister’s analysis of delays imputable to the CRA is limited to those incurred between the TCC order of February 26, 2013 and the assignment of the Applicant’s file to an appeal officer in November 2013, and consequently, at the initial level, cancelled interest for one month during that period (October 2013) to account for the delay. ...

. … Mr. Scotti was fully aware of the benefits he would derive from the purchase of a $5 million universal life insurance policy whose insurance premiums would be fully paid, for two years, by means of the amounts paid by Mr. ... Scotti, who, by his own admission, had no need for insurance at the time …. ...

. … Mr. Scotti was fully aware of the benefits he would derive from the purchase of a $5 million universal life insurance policy whose insurance premiums would be fully paid, for two years, by means of the amounts paid by Mr. ... Scotti, who, by his own admission, had no need for insurance at the time …. ...

She stated (at paras. 72-75), TaxInterpretations translation: … Mr. Scotti knew, or ought to have known, that he was participating, without any financial contribution on his part, in a scheme which would provide him and Mr. ... R. [2008-4063 (IP)G] …. In addition to all of this, Mr. Scotti was able to rely, on a daily basis, on the independent support and advice of the accounting firm he employs for his business, as well as the comptrollers who work for each of his 14 automobile dealerships. ...

. … It is my view that the tax opinions and representations set out in the Valuation Report were intended to advise a prospective purchaser as to the tax treatment they could expect if a purchase of Software was made. ... Krumm, IAC and its agents could each be considered to be a tax shelter “promoter”, as defined in subsection 237.1(1) …. ...