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" … The petitions before me are directed exclusively at the interpretation of the Income Tax Act for the sole eventual purpose of determining whether there needs to be a remission to the Receiver General of the 25 per cent tax applicable to non‑residents under s. 116(5) of the ITA. ...

Before granting the application, Gascon J indicated that: "the expectation of privacy with respect to business records such as those targeted by the Unnamed Persons Requirement is very low" "PayPal has not filed any evidence to support a claim that the Unnamed Persons Requirement is overbroad or reaches a disproportionate number of persons or transactions" "the information sought in the Unnamed Persons Requirement is required in the context of verification activities undertaken in good faith by the Minister to combat the underground economy … to determine whether the Unnamed Persons have filed their required tax returns" ...

. … Profitable realisation of the investment by disposal was an objective of the investment by the RCF partnerships from the beginning. ...

The taxable activity in each case was an investment in … Talison Lithium which was carried out on their behalf by their respective General Partners. ...

Coincidence of the identity of the sole director, the sole shareholder and the person by whom services are provided does not mean that the corporate decision to enter into a service contract and the actual formation of the contract can take place wholly within the individual’s head and be revealed, if at all, only when it suits him or her to reveal it. and that: The question … is whether the conduct of the parties viewed in the light of the surrounding circumstances shows a tacit understanding or agreement. ...

Tremblay case, Bédard J found that house-repair invoices, that did not give the house address or describe the precise nature of the work performed (and that were rendered in the name of entities that did not remit the GST), failed to satisfy the requirements of s. 3 of the Input Tax Credit Information (GST/HST) Regulations, so that the appellant’s related input tax credit claims were properly denied – and also found (at para. 25) that “the appellant did not truly acquire the supplies for which it claimed ITCs.” ...

In this case, the evidence indicated that, during a relatively short period of time, the appellant was duped by his partners and he was unaware that the corporation was having financial difficulties …. ...

In May 2008, the taxpayer arranged for the ½ co-ownership interests to be transferred to her. ...

The [definition] … by no means speaks to specifically allowing different financial year-ends for Quebec purposes. ...

In finding that Delia would be liable under an assessment made of him for the above amount plus interest under the Quebec equivalent of ITA s. 227.1 (s. 24.0.1 of the Tax Administration Act) but for the due diligence defence (under s. 24.0.2), Cameron JCQ found that Delia had taken reasonable steps “in establishing and maintaining a reliable accounting system” (para. 122), that the allegedly erroneous entry only “accounted for around 2.4% of the total gross QST … generated annually on sales” (para. 123) and (at para. 125): …[T]he inability of those at Motostar to substantiate with precision the entry does not in any way establish a lack of diligence, care or skill on the part of the director who had entrusted the accounting and the handling of the tax returns to them. ...