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. … I have no hesitation in concluding that the benefit sought by Birchcliff from the amalgamation was to obtain the tax attributes, the losses, of Veracel. ...

. … [T]he respondent was required to demonstrate, on a preponderance of evidence, not only that a certificate specifying the amount for which the corporation was liable had been registered in the Federal Court, but also that that amount had been returned unsatisfied in whole or in part. ...

However, TSI filed a Notice of Discontinuance on May 2, 2016 and the appeal was deemed to be dismissed on June 24, 2016 pursuant to s. 16.2(2) of the Tax Court of Canada Act (the “ TCC Act”). ...

The Queen, 2018 TCC 83-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) two individuals jointly controlling a company were acting in concert respecting the payment of dividends A company (“PES,” or the “Operating Company”) providing electricians’ services initially was owned on a 50-50 basis by two individuals – Smith and Scott, who each was an officer and director, and with Smith overseeing the work at various sites and with Scott responsible for most financial matters. ...

. … Visa acts as a financial intermediary by facilitating the transfer of payments between issuers, acquirers and merchants. ...

. … She registered for the summer semester and paid a single fee. All courses were taken consecutively or “one after the other”, over a ten week semester. ...

Graham J accepted the submission of the applicants (the designated partners of the partnerships) in connection with a Rule 58 determination that the Minister could not issue a valid Notice of Determination if the Minister had concluded that the partnership in question did not exist – so that the Notices of Determination were invalid. ...

(f) of the ECP definition for “the cost of … a right to acquire [a share]” did not apply given that “the word ‘cost’ contemplates an acquisition of an asset or other property” (para. 103), whereas “when a stock option is surrendered to the issuing corporation, the rights represented by that option [instead] are extinguished” (para. 122). ...

(f) of the ECP definition for “the cost of … a right to acquire [a share]” did not apply given that “the word ‘cost’ contemplates an acquisition of an asset or other property” (para. 103), whereas “when a stock option is surrendered to the issuing corporation, the rights represented by that option [instead] are extinguished” (para. 122). ...

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). ...