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. … Considered as a whole, the history of this investigation directly harms the integrity of the justice system and irreparably compromised the community’s sense of fair play and decency. ...

. … [T]he Assistant Commissioner … [also] simply stated the principle that errors or omissions by tax professionals “are not considered extenuating circumstances for the purpose of remission” and then treated it as a complete answer to the applicant’s submission. … Given the importance to the applicant’s request of the question of whether any errors or omissions by the tax professionals who assisted the applicant could constitute an extenuating circumstance or, more broadly, made it unreasonable or unjust to recover the 2005/2006 debt, it was essential that the Assistant Commissioner explain why he concluded that they did not. … [I]t is insufficient to simply state the rule without also explaining why an exception should not be made in this case. ...

The ARQ considered this to be abusive surplus-stripping, and applied the Quebec general anti-avoidance rule to treat most of the paid-up capital distributions as taxable dividends. ...

. … [S]ection 318 of the FCR should not be considered in isolation. Faced with a problem such as the one faced by Rémillard, the Court is capable of finding a solution that balances, to the extent possible, the objectives of meaningful review of administrative decisions, procedural fairness, and the protection of any legitimate interest in confidentiality while at the same time maintaining the open court principle …. ...

. … The GP Rule 30(2) in its latest iteration, which appears to enable any individual (including one outside of the corporation, such as its regular accountant) to represent it on leave, could not by any stretch of the imagination be considered a definition of the words “in person” in section 17.1. ...

Before finding that the Minister’s decision to reject was reasonable (which relevantly was all that was required), Walker J stated (at para. 107): I have considered the Bank’s … argument that the Minister must approve a proposed methodology if it is fair and reasonable. ...

In addressing Ontario’s argument “that the fuel and excess emission charges imposed by the GGPPA do not have a sufficient nexus with the regulatory scheme to be considered constitutionally valid regulatory charges” (para. 212), the majority first noted that “[t]o be a regulatory charge, as opposed to a tax, a governmental levy with the characteristics of a tax must be connected to a regulatory scheme” (para. 213), and then found (at para. 216) that to establish such nexus, there was no requirement that “the revenues that are collected be used to further the purposes of the regulatory scheme,” and that: Where, as in the instant case, the charge itself is a regulatory mechanism that promotes compliance with the scheme or furthers its objective, the nexus between the scheme and the levy inheres in the charge itself. ...

Whether the interest was taxable under the Taxation Act turned on when her damages were considered to have become “liquidated.” ...

Canada, 2021 FCA 96-- summary under Section 181.2 Summary Under Tax Topics- Excise Tax Act- Section 181.2 Aeroplan Miles were considered, by the sole Justice addressing the issue, to be gift certificates since no significant conditions to their redemption The appellant (CIBC) was charged by Aeroplan for the number of Aeroplan Miles that were credited to the cards of CIBC cardholders. ...

In rejecting the appellants’ arguments that the Part III assessments were invalid because there was one assessment for multiple purported capital dividends and the assessments had not been issued “with all due dispatch,” Smith J stated (at paras 110, 111, 113 and 137): I agree with the Respondent that the requirement that the Minister “examine each election” and “assess the tax, if any”, as required by subsection 185(1) must be considered in light of subsections 152(3) and 152(8) and section 166. ...