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. … [E]ven if ISAF were to be considered a subsidiary body of NATO … [and] despite the fact that ISAF employs civilian personnel like the Appellant, it is still a military body. ...

The Queen, 2020 TCC 11 (Informal Procedure)-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts no donative intent, as in Mariano The taxpayer participated in the same “Global Learning” charitable tax credit arrangement as had been considered in Mariano and under which he had claimed charitable tax credits based on a $5,000 cash gift and a supposed gift of licences valued at $25,056. ...

Russell J considered this pleading to be deficient, and found that, given that there was not much of a burden on the taxpayer regarding his “eligible individual” status, somewhat fluffy and poorly substantiated testimony of the taxpayer was sufficient to establish that the taxpayer so qualified for various periods in issue (other than those as to which the taxpayer had effectively conceded.) ...

The Queen, 2022 TCC 36-- summary under Estoppel Summary Under Tax Topics- General Concepts- Estoppel issue estoppel precluded reviewing compellability of documents from a Saskatchewan regulatory authority The taxpayer, who had appealed reassessments of three of her taxation years for which CRA had added approximately $2.8M in shareholder benefits to her income, brought a motion pursuant to Rule 86 to compel the Financial and Consumer Affairs Authority of Saskatchewan (“FCAA”) to turn over certain documents that she considered to be relevant to her appeal. ...

The Queen, 2014 DTC 1197 [at at 3749], 2014 TCC 266-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) highly discounted receivables purchased by non-resident affiliate were not "pig in a poke" Boyle J, after finding in McKesson that the taxpayer had been selling its trade receivable to its immediate Luxembourg parent (MIH) at discounts which were excessive from a transfer pricing perspective, recused himself from consideration of residual issues (respecting costs and the disposition of sealed documents) on the ground that he might no longer be considered to be impartial, as McKesson Canada, in its factum filed with the Federal Court of Appeal, had alleged that he was "untruthful and deceitful" in his reasons, stated "clear untruths" about him and alleged that he was not impartial (numerous paras. beginning at 4). ...

After finding that these gains were not income from a source, Woods J. went on to find (at TCC para. 44) that the distributions to the taxpayer also should not be considered under the surrogatum principle to have been received in lieu of income pursuant to a legal right because the amounts instead had been received pursuant to a fraud. ...

Johnson and Hammill, it cannot give rise to a source of income... and cannot be considered a business under any definition. ...

He then went on to note, with respect to the requirement that the taxpayer's employer carry on business outside Canada, that although "if the Canadian company's business is solely that of a placement agency, the business is not being carried on outside Canada simply by virtue that the personnel placed, conducted their activities outside Canada... if, however, the business is providing services by way of subcontracting to a contractor, which services must necessarily be provided outside Canada, then the business can be considered to be carried on outside Canada". ...

If this interpretation is correct, then the letter could reasonably be considered to be an application to extend time to appeal. ...

Woods J. accepted the taxpayers position that all of the dividends paid by Comcare to the Holdcos should be considered to come out of safe income and rejected the position of the Minister that only one-sixth of the $1.9 million safe income had been inherited by the Holdco. ...