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. … The Minister has not considered the objection as she should have done. … ...

Agence du revenu du Québec, 2023 QCCQ 3350-- summary under Subsection 18(12) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(12) the relative business use represented by a home office using the home’s gross rather than net area In deducting his home office expenses, the taxpayer determined the portion of his home that was used in his business of providing electrical engineering services (28%), which he calculated by dividing the square-foot area of the three rooms that he used in that business by the net square footage of his home, which was the area of the two floors (main floor and basement) as measured by the exterior dimensions, minus the areas taken up by the walls and minus the area of common areas (stairwells and hallways), which he considered to be used pro rata for business and personal use. ...

…In Jabel Image Concepts Inc v Canada, [2000] GSTC 45, the Federal Court of Appeal wrote at paragraph 12: When an Act uses different words in relation to the same subject such a choice by Parliament must be considered intentional and indicative of a change in meaning or a different meaning.... ...

The King, 2023 TCC 135-- summary under Interpretation/Definition Provisions Summary Under Tax Topics- Statutory Interpretation- Interpretation/Definition Provisions scope of a deeming provision is limited to what is clearly expressed in the provision In finding that, in the presence of a provision (s. 104(19))- which deemed the taxpayer to have received a dividend some time in its taxation year which straddled the taxation year end of the trust that made the s. 104(19) designation (to deem a dividend received by it to have been received by the taxpayer, its beneficiary) but which did not specify the particular time within the taxpayer’s taxation year in which this deemed receipt occurred- that such dividend should be considered to have been received by the taxpayer at the time at which it actually was received by the trust, D’Arcy J stated (at para. 55): Once it is determined that a deeming provision applies, one must then look at the actual wording of the deeming provision to determine what legal fiction is created. ...

S. 1010.0.2 provides that, notwithstanding the expiration of the period to file objections, the Quebec Minister may, within one year of a federal reassessment “make a reassessment for the sole purpose of taking into account elements that may be considered to relate to that assessment or reassessment.” ...

Sutton, considered that all of such deposits to his account were remuneration received by him, and imposed a late source-deductions remittance penalty under s. 227(9) on the appellant regarding its computed under-remittance. ...

Sutton, considered that all of such deposits to his account were remuneration received by him, and imposed a late source-deductions remittance penalty under s. 227(9) on the appellant regarding its computed under-remittance. ...

Sutton, considered that all of such deposits to his account were remuneration received by him, and imposed a late source-deductions remittance penalty under s. 227(9) on the appellant regarding its computed under-remittance. ...

The King, 2024 TCC 76-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) amounts that in fact had been paid were not deemed to have been payable notwithstanding any illegality CRA considered that the trustees of a family trust had improperly delegated their fiduciary powers to other individuals (the Rémillard Brothers) in violation of the trust deed and Art. 1275 of the Civil Code, so that the trust determinations to make distributions based on such improper delegation were a nullity, with the result that the distribution amounts were not “payable” as required by s. 104(6). ...

However, the TFSA submitted that the exemption from tax for an RRSP on business income from the disposition of qualified investments in s. 146(4)(b)) should be read into s. 146.2(6) given that the RRSP and TFSA regimes were “mirror images” of each other – so that “that the phrase ‘carries on one or more businesses’ in subsection 146.2(6) should be read so that a TFSA trust that carries on a business of trading investments under well-established common law principles should not be considered to carry on a business for purposes of subsection 146.2(6) when the business involves only trading in qualified investments” (para. 12). ...