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Essentially, Noël C.J. considered that the “activities” language in s. 132(3) indeed was adequate because the GST (a “transactional tax”) is therefore essentially only about activities, including those engaged here in the debate as to whether s. 132(3) or s. 150(1) applied in relation to them (para. 40). ...

Essentially, Noël C.J. considered that the “activities” language in s. 132(3) indeed was adequate because the GST (a “transactional tax”) is therefore essentially only about activities, including those engaged here in the debate as to whether s. 132(3) or s. 150(1) applied in relation to them (para. 40). ...

Although CRA on audit considered that $485,447 of the second dividend was an excess dividend referred to in s. 184(3), no Part III tax was assessed on the alleged basis that 9158 and 9102 each had made a s. 184(3) election (consented to by their shareholders) on $485,447, and assessed the appellant on the basis that he had received a taxable dividend of $485,447. ...

[I]t is difficult to see how the requirement for a lawful object, as set out in Articles 1413 to 1422 of the CCQ, could not be considered to be an essential condition for any contract, including a contract of partnership. … [T]he contention of the appellant could lead to absurd consequences. ...

. … The Delegate reasonably considered the length of the delays and recognized that certain time periods were not appropriate for interest relief and others had already been accounted for in the earlier reviews. … … [T]here were no circumstances beyond the Applicants’ control which prevented them with complying with their obligations to pay tax. ...

Lévesque, J.C.Q. considered this issue to turn in part on whether the taxpayer’s consent was “free and enlightened” as required by Article 1399 of the Quebec Civil Code. ...

In allowing the Crown’s appeal of 2010 and 2012, she stated (at paras. 75, 82): [T]he Tax Court’s concern about “when or how far into the future an advantage … will be considered as attributable to” abusive transactions did not justify a restrictive interpretation of the definition of advantage. ...

In affirming the ARQ position, Breault JCQ stated (at paras. 57, 68-69, TaxInterpretations translation): [I]n order for two housing dwellings or units in the same immovable to be considered a single housing unit for the purposes of TA section 274 (or ITA 54), they must be sufficiently integrated, one with the other, such that the owner can benefit from full enjoyment of the entirety. ...

In finding that, in light inter alia of the signed protocol, Mobile should be considered to have objected to the second reassessment (no. 1380), Cameron JCQ stated (at para. 44): The Minister … not only had acknowledged receipt of the written statement of the intention of the taxpayer to object to the assessment in force in 2012, but he agreed with the opposing party and with the Court to bring the debate to an early hearing on its subject matter. ...

Such a decision certainly cannot be characterized as a "considered position" in the sense that it was defined in Cameron v. ...