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Although the Court has concluded that the Income Funds were not qualified investments for RRSP purposes, and while it certainly finds that the Appellant had ulterior motives in connection with his RRSP, that is not sufficient to reach a finding that the Income Funds were “window dressing”. ...

The King, 2025 TCC 103 (Informal Procedure)-- summary under Paragraph 146.01(2)(d) Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(2)- Paragraph 146.01(2)(d) inferred Ministerial acceptance of late HBP withdrawals because CRA only challenged them on another ground The taxpayers bought a pre-built home in December 2020, withdrew from their RRSPs in 2021 in connection with the purchase, but made further withdrawals in 2022 in reliance on the home buyers’ plan (HBP) rules. ...

In finding (at para. 66) "that FHA was administering a government program in respect of homemaker services," as required by the preamble to s. 13(1)(b)(ii), Paris J stated (at para. 66) that "it is only necessary, then, to show some connection between the B.C. ...

Shortly after the plaintiff received CRA's first correspondence on the matter, FMC sent him a retainer letter, which he signed, offering to advise him in connection with the proposed reassessment. ...

Bountiful had no connection to the Church of Latter-Day Saints (the LDS church had explicitly rejected some key practices in Bountiful, including polygamy), nor the Fundamentalist Church of Latter-Day Saints (there is no such organization, but rather only people who self-identify as members), nor any other identifiable organization. ...

Accordingly, s. 245(1) of the Act as it applied in June 1987 denied the deduction of the interest along with fees that were incurred in connection with entering into the transactions. ...

The Minister argued that Lavallee applied where law enforcement officials were seeking evidence of criminal wrongdoing, and not in connection with a regulatory compliance regime. ...

The Minister argued that Lavallee applied where law enforcement officials were seeking evidence of criminal wrongdoing, and not in connection with a regulatory compliance regime. ...

Before completion of the IPO, the Fund, Trust, appellant and its general partner entered into a "Financing Agreement" in which they agreed that all financing expense in connection with the IPO, other than the underwriters' fee, were to be incurred on behalf of the appellant; and at the same time the appellant entered into an "Administration Agreement" with the Fund in which it agreed to administer the Fund and "as agent of the Fund" to pay for all outlays and expenses incurred by it in such administration. ...

The Queen, 2016 TCC 137-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) TCC had jurisdiction to determine that no lender equitable remedy (under Quistclose trust doctrine) attached to leveraged donation advances In connection with a leveraged donation arrangement, the taxpayers in the lending agreement directed the lender (“Capital”) to deliver the funds to a charity on their behalf. ...