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. … [T]here is no doubt that the law practice of the appellant, when the relevant circumstances are considered in their entirety, certainly qualifies as having a personal aspect. ...

The taxpayers considered it to be unfair that CRA had not issued any reassessment that they could appeal, and applied for an order of mandamus compelling CRA to reassess in some manner. ...

Although she accepted that these provisions provided for the seizure of the specified account information, she considered such seizure to be reasonable after weighing the “minimally intrusive” (para. 293) nature of the seizure (i.e., of banking information that the individuals already could be required under US law to provide) against (para. 349) “the need to protect Canada as a whole from the economic consequences of FATCA” (i.e., of the disruptive 30% U.S. withholding tax that would have been imposed in the absence of arriving at the IGA). ...

. … The Supreme Court has endorsed the principle that the underlying purpose of an expense must be considered in the context of the taxpayer’s business. ...

In the Federal Court judgment, Roussel J noted (at para. 5): He argued that since the shares acquired were subject to numerous blackout periods and he was considered an insider of ZCL for the purposes of the TSX and relevant shares legislation and regulations, the assessed value of the shares should not be more than 60% of the trading price on the date of purchase. ...

Boivin JA stated (at para. 7): [These] remarks … were ill-considered. ...

Krumm, IAC and its agents could each be considered to be a tax shelter “promoter”, as defined in subsection 237.1(1) …. ...

The Queen, 2020 TCC 16-- summary under Section 21 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Act- Section 21 appeal is not launched until Notice of Appeal is filed Similarly to the corresponding provision of the OBCA considered in 1455257 Ontario, s. 219(2)(a) of the Corporations Act of Manitoba provides that a proceeding commenced by a corporation before its dissolution can be continued as if it had not been dissolved. ...

The Queen, 2020 TCC 11 (Informal Procedure)-- summary under Judicial Comity Summary Under Tax Topics- General Concepts- Judicial Comity principle of judicial comity applicable to previous Tax Court decision on the same donation program The taxpayer participated in the same “Global Learning” charitable tax credit arrangement as had been considered in Mariano. ...

In confirming that CRA had not acted unreasonably in declining to recommend a remission order under s. 23(2) of the Financial Administration Act, Locke JA noted that CRA had “implicitly acknowledged the general intent noted in Montecristo … that GST/HST should be limited to consumption within Canada,” but had reasonably considered that “Goods purchased by non-resident consumers are only intended to be zero-rated if they are shipped to a destination outside Canada, or they are sent by mail or courier to an address outside Canada,” and further stated (at para. 23): The Assistant Commissioner concluded reasonably that the predicament in which Escape Trailer found itself … was caused not by any unintended results of the legislation, but rather by its failure to comply with any of the detailed conditions for zero-rating. ...