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Hogan J confirmed CRA’s application of s. 245(2) to reduce the taxpayer’s CDA by ½ the amount of the s. 40(3.1) capital gain. ...

He went on to state (at para. 35): …In the alternative, if the supply of the Aeroplan Supplies included multiple supplies, one of which was the separate supply of Aeroplan Miles, … the supply of the Aeroplan Miles was incidental to the supply of promotional and marketing services by Aeroplan to CIBC, such that the supply of the Aeroplan Miles is deemed by section 138 of the Act to be a part of the supply of the promotional and marketing services made by Aeroplan to CIBC. ...

The Queen, 2019 TCC 109 (Informal Procedure)-- summary under Subparagraph 256(3)(a)(iii) Summary Under Tax Topics- Excise Tax Act- Section 256- Subsection 256(3)- Paragraph 256(3)(a)- Subparagraph 256(3)(a)(iii) substantial completion had occurred by the time of the interim occupancy certificate The taxpayer and her husband built a house, which was near Lake Huron and a 2 ½ hour drive from their Brampton rental apartment and full-time employment, doing a large portion of the work themselves on weekends beginning in 2008, with the intention to retire there. ...

By conceding that the interest expenses paid in respect of the loans taken out to finance expenses totalling $62,280... the respondent recognized … that the appellant carried on a business during that period and that the expenses totalling $62,280 had been incurred in relation to his commercial activities. ...

She concluded (at para. 73): [T]he breach justifies the lesser sanction of the Suspension especially since there has been repeated non‑compliance involving receipts for expense amounts for activities outside Canada, it could only account for half of such expenses and the production of documentation and such receipts were not timely and the fact remains that PLM has still not produced all such receipts … ...

She concluded (at para. 73): [T]he breach justifies the lesser sanction of the Suspension especially since there has been repeated non‑compliance involving receipts for expense amounts for activities outside Canada, it could only account for half of such expenses and the production of documentation and such receipts were not timely and the fact remains that PLM has still not produced all such receipts …. ...

After quoting (at para.55) the statement in Sattva that “While the surrounding circumstances are relied upon in the interpretive process, courts cannot use them to deviate from the text such that the court effectively creates a new agreement,” noting (at para. 66) that “For a debt to be incurred, there must be an obligation to pay the amount of the debt,” and further noting (at paras. 69-70) that under “the common law doctrine of contribution as it applies to the payment of a debt by a joint debtor … ‘[i]f a debtor pays more than his equal share, he has a right to contribution in respect of the excess’,” Owen J stated (at paras. 77-78): [T]he evidence is that as of July 31, 2010 the Appellant had paid no amount in respect of the principal amount of the Second Loan to BDC or to any other person for the benefit of 1207330. ...

. … It is clear that, in the files in this case, the principles enunciated in the Jarvis case were followed. ...

She also noted (at para. 63): Brown [2013 FCA 111] … determined that documents seized in a criminal search could be admitted into evidence on the appeal of an assessment. ...

As a result … the penalty is in fact higher than 50%. As was pointed out [in McLeod v. ...