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In rejecting a Crown submission that the taxpayer was precluded from submitting that it was a s. 2(c) bank or used the equivalent of more than five full time employees, C Miller J stated (at para. 184) that the purpose of the s. 165(1.11) rule is that “the Minister knows the nature of the dispute and the quantum of tax at issue” (para. 184), that the Crown was requiring him to “look into the minutia of what is meant by a reasonable description of an issue” (para. 187), that the Crown “knew full well that there would be considerable evidence as to what GBL did … which encompasses activities that might constitute the provision of financial services (part of the Bank Act, subsection (2(c)) definition” (para. 190) and that “whether there was the equivalent of five full-time employees is subsumed into the employee issue generally” (para. 190). ...

Such an interpretation would clearly undermine the intent of the Parliament …. ...

., 2018 FCA 166-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) s. 103(1) likely applies to the allocation of most of the partnership profits at year end to a lossco that never had significant economic interest or risk in the partnership business Income account treatment of the profits realized by a condo-project limited partnership was avoided by the corporate partners (the Partnercos) of the partnership paying safe income dividends (out of the realized but unallocated condo profits) to their respective Holdco shareholders through the payment of stock dividends of preferred shares followed by a redemption of those preferred shares – in turn, followed by a sale by the Holdcos of the Partnercos to a public company with substantial resource pools (Nuinsco). ...

In finding that the Report was not protected by solicitor-client privilege, Southcott J stated (at paras 54-55): … I find that its dominant purpose when commissioned and generated was to inform the decision whether to proceed with the transaction and at what price. ...

The children … were declared as dependents of Mr. Rousseau for all the taxation years under litigation. ...

After finding that the value-shift transactions entailed an avoidance transaction given that their professed estate-freezing purpose could have been accomplished more conventionally (utilizing a s. 85(1) or 86(1) rollover), Noël CJ went on to find that they were an abuse of the basic capital gains provisions (ss. 38(b), 39(1)(b) and 40(1)(b)), stating (at para. 56, TaxInterpretations translation): [I]t is possible for the object and spirit of provisions in issue to have a larger rationale that that which emerges on a reading based on the words (See … Triad Gestco, paragraph 51). ...

D’Arcy J previously had directed that certain of the appeals proceed under the Court’s lead case rules (in Rule 146.1) – there were two lead cases under the general procedure and 23 informal appeals were held in abeyance. ...

Agence du revenu du Québec, 2018 QCCQ 9487-- summary under Subsection 323(1) Summary Under Tax Topics- Excise Tax Act- Section 323- Subsection 323(1) assessment could be made of director for unremitted QST even though assessment therfor of dissolved corporation was void The ARQ commenced a QST audit of a corporation (Motostar) after its voluntary dissolution by its sole individual shareholder (Delia) and assessed Motostar for some unremitted QST – and five months later assessed Delia for the same amount under the Quebec equivalent of ETA s. 323(1) (and ITA s. 227.1(1).) ...

In this instance, it is clear that the “prescribed information” required to support the Rental Rebate application was not included with the New Housing Rebate application …. ...

… [N]either the CRA nor this Court can impose the format in which this information must be provided to the CRA, as all the necessary information has already been provided. ...