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In finding that such expenses did not qualify for deduction under s. 8(1)(b), Lafleur J stated (at para. 28, TaxInterpretations translation) respecting the first ground of his action noted above: [I]t did not seek to recover any amount that would have been due in consideration of Mr. ...

These considerations were reinforced by the purposes of s. 227.1, which had been judicially stated to be “to strengthen the Crown’s ability to enforce the statutory obligation imposed on corporations to remit source deductions” (para. 25), whereas the Tax Court interpretation “render[ed] this purpose nugatory and pointless” (para. 26). ...

…[O]ne of the considerations that is listed as a relevant factor is the frequency or number of other similar transactions completed by the taxpayer. ...

In determining legal subordination, that is to say, the control over work that is required under Quebec civil law for a contract of employment to exist, a court does not err in taking into consideration as indicators of supervision the other criteria used under the common law, that is to say, the ownership of the tools, the chance of profit, the risk of loss, and integration into the business. ...

In addition, the fact that the requests may involve substantial documentation which the taxpayer may view as not proportional to the matter is not a relevant consideration (para 42) … In this case, there is no evidence to suggest that the CRA audit has been launched for any purpose other than to ensure compliance with the ETA, or that the request for information was so wide, extraordinary, or unusual as to give rise to questions about its legitimacy in the context of the audit (assuming that such a claim could be brought, in the face of the wide authority granted to the Minister to set the timing, scope, and nature of the audit …. ...

These transactions depended in part on the appellants being considered to have acquired units of an income fund ("FMO") from another income fund ("TOM") (which in turn had purportedly acquired the FMO units from an RRSP in consideration for issuing TOM units to it) at a cost equaling the units’ FMV, followed immediately by a distribution to them of capital gains that had been realized by FMO – with that distribution not reducing the ACB of their units by virtue of s. 53(2)(h)(i.1)(A) and (B)((I). ...

Under the agreement between JDI and IPPL, JDI accomplished its servicing of the equipment under its “services agreement” with IPPL by means of delegating to IPPL the performance of such services as its agent, in consideration for fees going in the opposite direction. ...

This requires consideration of whether the Sample Documents are, or record, communications made for the dominant purpose of giving or receiving legal advice. ...

The ARQ accepted that various salary expenses of CS Canada (of about $0.9M per annum) were incurred on the prosecution of SR&ED, but denied investment tax credits under the Quebec equivalent of s. 127(18) on the basis that the contractual consideration paid by P&W constituted “contract payments” under the Quebec equivalent of the definition of that term in ITA s. 127(9), i.e., on that basis that the SR&ED was performed on behalf of P&W. ...

The Minister is bound to apply the ETA irrespective of policy considerations. ...