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To address increasing mobility issues of his wife, the taxpayer replaced these with a deck with a 5-foot wide stairway and aluminum railing – and claimed the $10,000 home accessibility tax credit. ...

Krumm, IAC and its agents could each be considered to be a tax shelter “promoter”, as defined in subsection 237.1(1) …. ...

The Queen, 2020 TCC 6-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) taxpayer not subject to penalty where its CPA firm made inexplicable errors D’Auray J found that a one-man corporation that had a business of constructing (through using third-party contractors) and selling about 10 or 20 new homes per year had not been demonstrated by the Crown to be liable for gross negligence penalties for failure to report in its GST returns two of the home sales it made in the 2 ½ year audit period. ...

Spiro J set the stage by noting (at para. 14) that “In order for the Minister to assess a policyholder under … subsection 148(1)… the “adjusted cost basis” of the policy to the policyholder immediately before its disposition must be determined,” and by stating (at para 25): The courts have consistently held that unless the Minister’s assumptions of fact are sufficient to support the assessment under the relevant legislation, the onus does not shift to the taxpayer. ...

. … There is no evidence that any GST/HST remittances were diverted to assist with the business activities. ...

. … He bills the Government of Ontario for such [medical] services in his own name. ...

After March 21, 2016, the object, spirit and purpose of the Reduction Provision, as amended, was to refer to the adjusted cost basis of a policyholder’s interest in the particular policy in order to determine the amount that could be added to the capital dividend account of a corporate beneficiary, even where that beneficiary was not the policyholder. ­­­­­­­­­­­­­­­­­­­ ...

. … The respondent did not introduce any evidence to rebut the accountant’s account of the events. ...

. … …The facts in Schwartz [for losses arising from the retraction of an employment offer] are too different for the decision to be meaningful to the present inquiry. ...

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