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., 2019 FC 506, aff'd 2020 FCA 85-- summary under Subsection 289(3) Summary Under Tax Topics- Excise Tax Act- Section 289- Subsection 289(3) requirement to show all customers with significant purchases Campbell J authorized a requirement by the Minister for Roofmart to disclose the particulars of all its customers who in any of the past 4 ½ years had made purchases of construction materials from Roofmart in excess of an annualized total of $20,000. ...

These requirements are essentially the same as in the common law provinces …. ...

The Queen, 2019 TCC 254, aff'd 2022 FCA 66-- summary under Subsection 82(1) Summary Under Tax Topics- Income Tax Act- Section 82- Subsection 82(1) payment was dividend even though no declaration In finding that a corporation should be treated as having paid dividends to its shareholder, so that CRA validly assessed the shareholder under s. 160 for a tax debt of the corporation, even though no dividend had been declared, and the only evidence of the payment of a dividend was the cash movements and the corporation’s subsequently-fired accountant issuing T5 slips to the taxpayer, MacPhee J stated (at para. 23): [A] reported dividend, even if not in compliance with the provincial statute, remains valid for tax purposes …. ...

The Queen, 2019 TCC 265-- summary under Land Summary Under Tax Topics- General Concepts- Fair Market Value- Land FMV of home potentially reduced by spouse continuing to live there After finding that s. 160 applied on the basis that ½ of the beneficial ownership of the family had been transferred for nominal consideration to the taxpayer by her husband, a tax debtor, MacPhee J also noted (at para. 34) that “it could be argued that the value of what was transferred by Mr. ...

Canada, 2020 FCA 90-- summary under Section 14 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 14 marginal notes may be considered as part of the interpretive process Before going on to accord a restrictive interpretation to s. 149(1)(d.5) based on the wording of the marginal note to s. 149(1)(c), which contained similar wording, Mactavish JA stated (at para. 54): [I]n accordance with section 14 of the Interpretation Act … marginal notes do not form part of a statute, and are only inserted for ease of reference. ...

., 2020 FCA 125-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis prior decision of the FCA that “manifestly overlooked [the] established line of cases” was not to be followed After noting the Crown’s reliance on the FCA’s finding in Freitas that a statute-barred reassessment was voidable rather than void, Noël CJ stated (at para. 55): I agree with the respondent that Freitas is not authoritative on this point as the Court manifestly overlooked this established line of cases and did not address the reasoning behind it …. ...

.), Masse DJ allowed a significant portion of the claimed expenses – but disallowed others, for example, only allowing the expenses of the taxpayer’s cell phone but not his two land lines. ...

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The Court is guided by the rules of statutory interpretation in Canada Trustco … and by precedent. ...

Rattai, 2022 FCA 106-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Court is not bound by an admission shown to be nonfactual Monaghan JA stated (at para. 20): The Tax Court is not bound by an admission that is shown, through properly tendered evidence, to be contrary to the facts …. ...