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The Queen, 2021 TCC 47-- summary under Paragraph 142(2)(a) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(2)- Paragraph 142(2)(a) trucking company was considered to make an immediate on-supply of fuel to truckers in the country where it acquired fuel at service stations The taxpayer, which used its trucks, and independent contractors as drivers (a.k.a., contract truckers), to transport freight in Canada and the U.S, paid the "trip fee" specified in its agreements with the drivers for each trip. ...

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. ...

In determining whether there was substantial renovation of the Craven Road property and of the second property (the “Fourth Street” property) both parties accepted the use of the second of the three methods referred to in GST/HST Technical Information Bulletin B-092 for measuring whether a renovation had been “substantial” (with 90% appearing in B-092 as the minimum percentage for a property to be considered as having been “substantially renovated”). ...

In Montour, Bourque, J. had found that s. 42 was constitutionally inapplicable to the Mohawks in that case, who had also failed to pay duty on tobacco products: by reason of the circumstances of the case before her warranting a departure from the framework developed in Van der Peet ([1996] 2 S.C.R. 507) in respect of Aboriginal rights- so that the applicants' participation in the tobacco trade should be considered protected by an Aboriginal right to freely trade; and by reason of an inferred meta-treaty (the Covenant Chain) having been unjustifiably breached by s. 42 because the Crown had not discussed tobacco-related issues with the Mohawks prior to the passage of the Excise Act. ...

., after referring to the Minister's argument that Article 13(5) did not exempt the gain because the taxpayer was "not resident in Austria, and also because the tax in issue is not imposed on the basis that [he] is the alienator of the shares, but by the operation of the attribution rule in subsection 75(2)," stated (at para. 64): Justice Miller rejected that argument because he considered it inconsistent with the language of Article XIII (5), and the apparent premise for another provision of the Canada-Austria Income Tax Convention, Article XXXVIII (2). ...

The T3GR forms reported those RRSPs (but not that of the taxpayer) which were considered to be subject to tax on various bases including the holding of non-qualified investments, and CRA assessed such tax accordingly. ...

The T3GR forms reported those RRSPs (but not that of the taxpayer) which were considered to be subject to tax on various bases including the holding of non-qualified investments, and CRA assessed such tax (including, apparently, Pt. ...

. … The interpretation of the Trust Indenture which they [the petitioners] urge me to adopt is based on the same arguments that the Reassessment officer considered and rejected. ...

The group owned all or part of three office towers in a complex in Malaysia, and PSC argued that the office space allocated to its Malaysian branch could change from one tower to another depending on operational needs – so that the three towers should be considered a single site. ...

Wagner and Gason JJ. stated (at paras 17, 19 & 20): Solicitor-client privilege has evolved from being treated as a mere evidentiary rule to being considered a rule of substance and, now, a principle of fundamental justice… …[F]acts connected with that relationship (such as the bills of account at issue in Maranda [2003 SCC 67, [2003] 3 S.C.R. 193 at paras. 33-34]) must be presumed to be privileged absent evidence to the contrary…. ...