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CRA considered that the substantial completion date was January 13, 2020, being the date that the local town conducted its final inspection of the property. ...

If renovations which are expressly provided for under the Act must be so substantial as to require virtually gutting all of a pre-existing premises to qualify for a rebate, additions, for which there are no express provisions in the Act, should (if they are to be considered at all) presumably be more substantial yet. ...

However, Bocock J. further indicated obiter that he would have considered the payment to have been paid otherwise than as consideration for "the supply" under the EPA, i.e., it was not consideration for the supply thereunder of electricity. ...

" (p. 6529) In addition, the agreement could not reasonably be considered to be designed for the purpose of the government acquiring an interest in the taxpayer's property for purposes of s. 12(1)(x)(viii) given that in the circumstances the government's contribution was in the nature of a grant, subsidy or forgivable loan instead, as described above. ...

As stated in London & Thames Haven, an asset’s profitability is an element to be considered in assessing its capital value.... ...

Regarding the position of the Minister that amounts that do not constitute actual income earned ("phantom income") should not be considered as safe income, Dussault T.C.J. indicated that this position failed to reflect that income for tax purposes is not a logical and coherent concept that reflects reality and that the wording of s. 55(2) (and, in particular, s. 55(5)(c)) "does not permit any such orientation in the name of a perhaps desirable but non-existent realism" (p. 685). ...

Double taxation can only be considered to exist where it is equitable and/or the language of the taxing Act is clear and unequivocable. ...

Sommerer, 2012 DTC 5126, 2012 FCA 207-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- Section 104- Subsection 104(1) Austrian foundation likely not a trust Before allowing the taxpayer's appeal from an assessment made on the basis that s. 75(2) applied to attribute a capital gain realized by an Austrian private foundation (founded by the taxpayer's Austrian father) to the taxpayer, Sharlow J.A. noted (at para. 38) that she considered it a "doubtful proposition" that the foundation was a trust, even though the taxpayer's counsel had not argued this alternative basis for overturning the assessment. ...

. … For example, if items are sold in large volumes in a wholesale market, the fair market value of the volumes sold in that market will be less than the aggregate of the values of the items considered individually that make up those volumes. … When a court is required to determine the fair market value of an asset for which there is no market that permits a direct comparison, it may be necessary to consider the transactions in some other market, subject to such adjustments as may be appropriate to the case, such as a blockage or volume discount. ...

A sum is considered certain when it can be made certain. By this, I take it, is meant where it can be determined by computation. ...