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Paris J instead found that what should be considered to have occurred was that Armour used all of the $2.4 million credit owing to it by the Province (which was not allocated under any of the agreements with the Province) to acquire the fee simple interest to the property on behalf of ADL and that, in exchange for that $2.4 million, Armour acquired the new (nominal-rent long-term) leasehold interest in the property from ADL Thus, the $2.4 million was a capital expenditure to acquire a capital asset (being such leasehold interest). ...

. … [M]easuring and controlling Phe intake is properly characterized as administration of the therapy and not as control of X’s diet with the consequence that the correct way to apply these rules [in subsection 118.3(1.1)] is to consider that the time spent determining the amount of Phe to be consumed and actually consumed, including the time spent logging Phe intake, should be considered as part of the 14‑hour a week average. ...

The taxpayer considered half of the funds so transferred as hers and as a loan, and the taxpayer and her husband had an oral agreement respecting monthly repayments that would be made upon the Company becoming profitable. ...

The Queen, 2012 TCC 240, Campbell J. considered that Parliament intended that the words “near equal basis” in the definition of “shared-custody parent” to mean “only a small difference between the amounts of time spent with each parent”. ...

By the 2009 MOC, students enrolled on the validated courses were to be "considered members of [MU]" but were not entitled to receive university student ID cards and access to university facilities and resources was very limited. ...

He then quoted the statement in Re Hetherington (deceased) [1990] Ch 1 that “even where a decision of a point of law in a particular sense was essential to an earlier decision of a superior court, but that superior court merely assumed the correctness of the law on a particular issue, a judge in a later case is not bound to hold that the law is decided in that sense,” and then concluded (at para. 8): It follows from those observations, and from the way in which the issue of RCF III as a taxable entity was considered in RCF III, that the view in RCF III that the partnership in that case was a taxable entity is not binding in these proceedings. ...

., it did not matter that the supplier was the mooted CCPC rather than the non-resident), but found that they did not deal at arm’s length, stating (at paras 58 and 59): …Under paragraph 251(1)(c) of the ITA, the requisite inquiry is entirely factual, and the ability to set the terms of the supply agreement must accordingly be considered in context. … [I]n light of ADC’s near-total economic dependence on Seawind Corp., the fact that the owner of the latter company dictated (and was able to dictate) the terms of the relationship between the two companies is a very relevant factor in determining whether the two were dealing at arm’s length. ...

In the Markou case, Paris J found (at para. 108) that “ donative intent in civil law, as in common law, is always an essential element of a gift, even a partial gift,” whereas here “there was just one interconnected transaction and no part of it can be considered a gift that was given in expectation of no return” (para. 109). ...

. … While he was entitled to express his views about the impact of the CRA’s error and the fact that relief should be considered in his reasons, he should have limited himself, in the judgment, to dismissing the appeal. … ...

Although this advocacy was subordinate to its poverty-reduction purpose, it nonetheless was considered by CRA to be devoting most of its activities to (non-partisan) political activities so that it was well outside the safe harbour in ITA s. 149.1(6.2) for ancillary political activities. ...