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The basement unit, which represented 54% of the triplex, had been occupied by him for use as his residence and a home office since his purchase of the triplex in 2002. ... In confirming the ARQ’s reassessment made on the basis that only 54% of the taxpayer’s gain was eligible for the principal residence exemption, Breault JCQ stated (at paras. 57, 68 TaxInterpretations translation): Breault JCQ stated: [I]n order for two housing dwellings or units in the same immovable to be considered a single housing unit for the purposes of TA section 274 (or ITA 54), they must be sufficiently integrated, one with the other, such that the owner can benefit from full enjoyment of the entirety. … [N]o transformation or modification of much significance was made to the Triplex in order for the three units to be linked in some manner to each other. ...

In finding that the taxpayer’s claimed losses (except for an $8 million overstatement of the 2002 loss due to an “egregious error” – for which a gross negligence penalty was sustained) were fully deductible, Spiro J noted (at para. 191): Friedberg stands for the proposition that straddle traders may report the results of their trades for tax purposes on a [realization] basis that does not reflect the true economic results of such trades.” ...

. … Just because the documents are not part of the evidentiary record does not mean that they are not part of the Court record and, it should be recalled, it is the documents in the Court record that are subject to the open court principle. Regarding the open court principle, he referred (at para. 27) to the observation in Sierra Club, 2002 SCC 41, at para. 36 that “[t]he link between openness in judicial proceedings and freedom of expression has been firmly established by this Court,” and stated (at paras. 30-31): Section 26 of the FCR is clear. The open court principle allows any person to inspect a court record and any annex "that is available to the public" …. ...

Expense- Damages legal fees incurred to recover misappropriated funds were not capital expenditures The taxpayer (Mobile), which was owned by the Waibel family in Europe, sold its two Toronto properties in 2002 and 2003 for $7.3 million, with $7.258 million of that sum being diverted by one of its directors (Black) without the authorization of the family. ... The result: the receipt of amounts, as interest, that was not a capital transaction, and that was income arising from property, the property being Black's obligation arising from the misappropriation, as confirmed by the legally binding effect of a settlement. … The analogy with the Kellogg and Evans cases is not perfect, because the former involved a business and the latter involved income from a trust, but it is sufficient to convince us that an expense is not capital in nature simply because the expense is not recurring or extraordinary. ...

. … Splitting the ownership of the building and the ownership of 9118, which continued to operate the [residence], had only one goal, to minimize the taxes payable. ... Godcharles was the sole director of all aspects of the transaction, from the purchase of the land in 2002 to the sale in 2006, with all the other plaintiffs seemingly absent from the entire negotiation. ...

., 2021 QCCA 605-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees incurred to recover a misappropriation of substantially all the taxpayer's assets were currently deductible The taxpayer (Mobile), which was owned by a German family, sold its two Toronto properties in 2002 and 2003 for $7.3 million, with most of that sum being diverted by one of its directors (Black), without the authorization of the family, by lending it at 2% interest to his company, which was or became insolvent. ... The ARQ reassessed to deny the deduction by Mobile of legal and accounting fees incurred by it in investigating the disappearance of the sales proceeds and in relation to the Superior Court action, primarily on the basis that they were capital expenditures (TA, s. 129, similar to ITA s. 18(1)(b) – although TA s. 128, similar to ITA s. 18(1)(a), was also invoked). ...