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In rejecting the taxpayers’ submissions that “all circumstances, including personal family circumstances and personal estate planning goals must be considered” (para. 90) and that the income and loss allocation methodology could be supported from the standpoint of estate planning objectives, he stated (at paras. 94, 97): [T]he reasonable business person would only consider factors relevant to their own business considerations having regard to their own business interest. ...

Favreau J then stated (at paras. 92-93): Since the MGICs, as a group of persons, controlled the Federation and the Federation controlled ProRé, the MGICs must be considered to also control ProRé by virtue of the simultaneous control principle set out in subsection 256(6.1) of the ITA, both immediately after and immediately before the disposition by the MGICs of the Class A shares of ProCap to ProRé. ...

The Queen, 2020 TCC 64, aff'd 2021 FCA 142-- summary under Subsection 152(6) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(6) a CRA policy to adjust loss carrybacks, to a reassessed year, beyond the s. 152(6) period, had no statutory authority The Minister assessed the taxpayer in 2010 under s. 160 respecting a transfer of $1 million in property made to it by an affiliate (“661”) for no consideration in 2003 at a time that CRA considered that 661 had an unpaid tax liability for 2000. ...

NewAgco US charged what James Mann considered to be a reasonable mark-up over its costs, and paid fees to AgraCity for logistical and other related services. ...

. … I cannot find that CRA’s “special mail services request form”, albeit presumably with a Canada Post “tracking number” stamped or affixed thereon, can reasonably be considered, “the post office certificate of registration of the letter or a true copy of the relevant portion thereof” per subsection 335(1). ...

Sommerfeldt J stated (at para. 29) that he considered that this statement had been made to him in order to persuade him at the time to not to strike out the other Crown pleadings at issue. ...

He considered that, normatively, 3295940 should have been caused by s. 55(2) to have realized a capital gain of $31.5M on Step 4. ...

In finding that the vendors, and Abacus and NH Properties, were not dealing with each other at arm’s length, Boyle J stated (at paras. 155, 161): Given the agreement for Abacus to pay a premium to the co-owners to purchase the co-owners’ interests … the steps and the amounts in the series of transactions cannot be considered to reflect ordinary commercial dealings. … Harvard Properties, Abacus and NH Properties clearly acted together to dictate [the] Newcos’ actions from their inception and throughout the closing of this series of transactions. ...

CRA considered that such reduction occurred, so that virtually none of Stock Dividend 2 came out of SIOH of the taxpayer respecting its shares of Newco 3 (see 6). ...