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Vavilov, 2019 SCC 65, [2019] 4 S.C.R. 653-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning administrative decisions must have regard to the provision’s text, context and purpose In connection with noting that a reasonableness review of an administrative decision extends to a review of the administrative body’s approach to statutory interpretation, the Curt stated (at paras. 118, 120): Those who draft and enact statutes expect that questions about their meaning will be resolved by an analysis that has regard to the text, context and purpose, regardless of whether the entity tasked with interpreting the law is a court or an administrative decision maker. ...

In finding that the taxpayers realized capital gains, Rochette JCA noted the absence of any connection between the taxpayers’ employment and real estate or of prior dealings in real estate, their initial intention of generating additional income on retirement and the decision to sell being brought on by changed circumstances, the low cost in dividing into co-ownership units and the low commercial risk associated with this step, and the sale of all the units occurring within the same year. ...

The Queen, 2020 TCC 34-- summary under Subsection 261(3) Summary Under Tax Topics- Excise Tax Act- Section 261- Subsection 261(3) In connection with a purchase of a dental practice (by the taxpayer, or by a partnership between him and the vendor – those facts are not clear), on February 29, 2012, the taxpayer paid the vendor $85,013.50 in HST in addition to the purchase price and, following a change in accountants, filed GST/HST general rebate application dated February 12, 2016 seeking a rebate of tax paid in error in the amount previously paid. ...

Attorney General of Canada, 2020 QCCA 697-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault abusive and wrongful CRA audit conduct did not engage punitive damages CRA made unreasonable reassessments with the knowledge that they were contrary to advice received from Rulings, offered in a settlement offer to settle elements that it knew it was going to abandon, failed to honour a commitment to give notice of the reassessments and delayed disclosures under the Access to Information Act process and made an inquiry with the Bermuda authorities that falsely stated that it was made in connection with a "criminal" investigation. ...

They described the conduct of the assistant director in connection with their complaints as harassing, and claimed that the award constituted damages for personal injury and violation of their rights under their collective agreement, and should be treated as a personal injury award that was non-taxable under s. 81(1)(g.1). ...

., 2020 FC 1044-- summary under Subsection 289.1(3) Summary Under Tax Topics- Excise Tax Act- Section 289.1- Subsection 289.1(3) refused addition to a disclosure compliance order of a condition that CRA give notice before disclosing the information to another authority The Minister sought a compliance order under s. 289.1(1) to compel the respondent (“EEIGI”) to provide certain access, assistance, information and documentation sought by the Minister in connection with an audit (the “Required Information”). ...

He also found (at para. 133) that various trips (treated by the ARQ as having been personal) had been established by the taxpayers to be “necessary and incidental to trips that were solely commercial,” including some helicopter-ferrying to close down a fishing camp that had been used for client entertainment, and the helicopter’s use in connection with training a pilot. ...

It purchased three pieces of equipment for use exclusively for the handling of materials already gathered by a cable shovel in connection with the washing, sorting and crushing of the various products. ...

., 2021 SCC 49, [2021] 3 S.C.R. 590-- summary under Treaties Summary Under Tax Topics- Statutory Interpretation- Treaties additional consideration in Treaty context of giving effect to the contractual bargain Before considering whether the taxpayer’s use of a capital gains exemption provision in the Canada-Luxembourg Treaty was an abuse under s. 245(4) given that the taxpayer was a conduit corporation rather than a corporation that had a significant economic connection to Luxembourg, Côté J stated (at paras. 29, 35-6): Like all statutes, tax legislation must be interpreted by conducting a “textual, contextual and purposive analysis to find a meaning that is harmonious with the Act as a whole” …. ...

In connection with its appeal of the CRA denial of these rebate claims, CIBC brought a motion for its appeal to be allowed on the basis that the substance of the supply was already determined in the 2009 Decision. ...