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. … This result would be extremely difficult for the Canada Revenue Agency to audit. ...

. … ...

In finding that ss. 128.1(1)(b) and (c) did not apply, Smith J stated (at para. 35): [T]he effective date upon which the Appellant became a resident of Canada … was when the Canadian dairy farm was acquired on June 15, 1998. ...

The CRA has already allowed home office expenses of $1,763 for 2012 and $2,333 for 2013 as well as office supplies in the amount of $361.00 pursuant to subsection 18(2) …. ...

On the basis of the construction invoices and photos and on the basis of giving the taxpayer the benefit of the doubt by treating “substantially all … as indicating no less than 90%” (para 11), Russell found that the rebate application was submitted more than two years after substantial completion of the renovation project, thus rendering per s. 256(3)(a)(iii) ETA the rebate as not available. ...

The evidence has established that JA is seriously lacking in ability to engage in social interactions … substantially all of the time. ...

. … I cannot find that the loan was repaid before the end of Steel's 1988 taxation year. ...

It was only in 2012 when Vocan started to supply assessment reports to Misir & Company, a personal injury law firm that informed Vocan that HST should be charged and collected on their reports, that Vocan then resumed charging insurance companies HST for assessment reports in the 2012 Period. ...

Owen J rejected the CIBC position- that such loss was deemed by s. 39(2) to be a capital loss from foreign currency and therefore was excluded from the application of the s. 40(3.6) stop-loss rule, which applied only if the loss were viewed as having arisen from the disposition of the subsidiary’s shares – indicating that this position was inconsistent with a statement in the BMO case that: “[t]he gain or loss arising as a result of a disposition of a particular property was (and still is) determined under subsection 40(1)” before any application of s. 39(2). ...

In rejecting their submission (at para. 8) “that 201 was merely a conduit for their money” so that (similarly to Borys) 201 had received the funds from them on behalf of Dandy, Graham J drew an adverse inference from their failure to call a key witness, and noted (at para. 10) and that, during the audit “the Appellants reiterated that their loans had been made to 201” and it” was only when their claims were denied that the Appellants first raised the idea that they had actually lent money to Dandy or Indiva [the other small business corporation]” (para. 12) Graham J concluded (at para. 30): … Had they structured their affairs differently, they may have been successful in claiming ABILs, but in tax law form matters. ...