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Cassell would reasonably be considered an employee of WPNL: his stated objective was to grow the business of WPNL (rather than of ICL); ICL did not conduct its services business in a business-like manner (e.g., no invoicing or written services agreement with WPNL); his duties remained the same as when ICL owned the retail business; ICL’s compensation pattern (fixed remuneration plus a year end bonus) was typical of a senior employee and that compensation structure also ensured that ICL had no risk of loss; although ICL had a rental operation, the rented properties were gas bars and convenience stores (with independent operators) that served as outlets for products of WPNL’s retail business and ICL did not pursue remedies for rent arrears where this would adversely affect that business. ...

The evidence, considered as a whole, shows that the Appellant wished to enhance shareholder value through the Spin‑off.... ...

In finding that s. 160 did not apply to the transactions, Rossiter CJ stated (at paras. 136-138, 147): The purchase by Nuinsco of the common shares and the preference shares issued in the Second Stock Dividend is, in my view, an indirect transfer of property from Partnerco to the Appellant, when considered in conjunction with the steps leading to and including the Nuinsco Loan. … HLP loaned an amount in question to Nuinsco that would have been otherwise able to be distributed to Partnerco and its fellow partners. ...

CRA assessed GEM on the basis that its construction services division was providing construction services to the Owners, whereas GEM considered that it was contracting as agent for the Owners. ...

In finding that this test was satisfied, Boyle J stated (at para. 12, TaxInterpretations translation): In accordance with the Quebec law applicable to Mika and the trust, …from the moment that Mika was born alive and viable, he was retroactively considered as a beneficiary, indeed as a person, from his conception, insofar as the laws of general application respecting the public interest were concerned, and as the interests of Mika required. ...

Favreau J upheld the s. 15(2) assessment, on the basis that he considered that the dividend payments gave rise to indebtedness of the individual to the corporation under the unjust enrichment principle. ...

In Barthels, … Hershfield TCJ considered that subsequent cancellation of support arrears where a custodial child had moved to the claimant parent’s residence did neutralize the original requirement to pay support amounts. … Russell J further stated (at para 19) My preference as to these two lines of authority is that represented by Barthels. ...

In findng that Amoco was not entitled to deduct the claimed interest, Hogan J agreed (at para. 57) that "the economic substance of the Key Transactions must be considered," but stated (at paras 58, 60, 68): …The language used in subsection 16(1) of the ITA stating that the payment is “deemed to be interest on a debt obligation held by the person to whom the amount is paid or payable” reflects Parliament’s intention that both parties receive symmetrical treatment. ...

. … Certainly the Minister had encouraged the Appellant in February 2014 when the NPR application was denied to submit a NRRPR application; signalling that the Minister considered that the Appellant might well qualify for that rebate. ...

Miller observed that a person could not be considered a de facto director where the person, …did not believe he was a director and he never thought he had any authority to advise, influence or control, the management or direction of the company. ...