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The taxpayer ultimately pleaded guilty to trafficking charges but, in connection with sentencing, asserted that his involvement was quite limited and that he did not share in the profits. ...

Both were now Canadian citizens, and neither one has any real ongoing connection with the U.S. ...

In rejecting Roofmart’s reliance on the statement in Hydro-Québec that "[w]hen the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition," Rennie JA stated (at para 37) that this “passage is not a legal test but analysis of whether, on the facts of that case, there was an ‘ascertainable group’ and whether the information was required for the purposes of verifying compliance,” and that ”the suggestion in the reasons that the information sought was available through other means and therefore could not be obtained through a UPR is inconsistent with this Court’s jurisprudence, and ought not to be followed.” ...

Furthermore, on January 15, 1999, he was entitled to receive a $52,617 transitional allowance in connection with his electoral defeat, but with payment on this amount being stopped because an investigation had been initiated into the misuse of the 1998 payments received by the taxpayer. ...

The connection of the consumption or use of the Subject Services to the course of the employee’s employment activities is even more tenuous and remote in the situation where a spouse or a child of the employee received a Subject Service. ...

Before so concluding, she also noted (at para. 45): In order for multiple shareholders to collectively exercise de jure control of a corporation, there must be a sufficient common connection between them, such as in a voting agreement, an agreement to act in concert, or business or family relationships (Silicon Graphics...). ...

After having indicated (at para. 23) that the reasonableness of the letters turned on a test of whether there may be considered to be “a rational connection … between the information sought and the administration and enforcement of the ITA,” Fothergill J rejected a submission that the request letters sought foreign-based information and that they should have been issued under s. 231.6, stating (at paras. 37, 43): I am satisfied that Dr. ...

In connection with its appeal of the denial of its rebate claims (and PC Bank’s appeal of assessments of other periods for its failure to charge GST on such supplies) CIBC brought this motion that its appeal be allowed on the basis that the substance of the supply was already determined in the 2009 Decision (or an order precluding the Respondent from introducing evidence inconsistent with the 2009 Decision regarding the substance of the supply). ...

In connection with addressing the CRA denial of SR&ED claims for six of Airzone’s projects, Hogan J made a number of general observations, including that: The taxpayer is required to demonstrate satisfaction both of “how factors,” namely “that the work was carried out by way of systematic investigation or search through experiment and analysis of a hypothesis … [and the] results of the work must also be preserved” (para. 5) and also a “why factor,” namely “that the work was carried out to resolve technical uncertainties that could not be solved through standard procedures and methods” (para. 6). ...

The Queen, 2022 TCC 39-- summary under Subsection 16.1(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 16.1- Subsection 16.1(1) confidentiality order granted respecting JV documents whose public disclosure would breach a confidentiality agreement The taxpayer (Shell) realized a capital loss on its disposition of its interest in a partnership (“SCU”) to Canadian subsidiaries of PetroChina in connection with establishing a joint venture with the PetroChina group (the “Groundbirch Joint Venture”) for the development and production of natural gas. ...