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Other legislative amendments made between 2009 and 2012 touch on aspects concerning residency in Canada and the income that can be considered for deduction purposes, which were not relevant in this case. [24] In my opinion, it is clear that Parliament's intention was always to authorize the deduction to encourage Canadians’ mobility, and the conditions that must be met to be entitled to this deduction reflect this objective of Canadian policy. ...

In 1977 the appellant saw what he considered to be a very promising mare for breeding purposes, "Jemarjo Princess” ("J.P. ...

None of these, in my opinion, can, by any definition that I’m aware of of the word “structure” be considered to be a structure. ...

The concepts of “property” and “transfer” were carefully considered in the leading decision of President Thorson of the Exchequer Court of Canada involving the Income War Tax Act in the case of Fasken v. ...

The Appellant notes that the CRA has held the Appellant’s claim for the $9,902,767 of input tax credits in abeyance pending the outcome in these appeals. [15] The Respondent argues that the amount at issue, after taking into the 50% rebate for public service bodies, was $7,256,080 comprised of:- $2,629,689 for the Appellant’s GST reporting periods ending between January 1, 2006 and March 31, 2010;- $9,252,782 for the Appellant’s GST reporting periods ending between April 1, 2010 and January 31, 2012; minus- The 50% rebate for public service bodies. [16] The Respondent has assumed that the public service body rebate was $4,626,391 ($2,629,689 plus $9,252,782- $7,256,080). [17] I agree with the Appellant that the $9,902,767 in respect of the reporting periods of the Appellant ending between February 1, 2012 and March 31, 2023 should also be considered since the Appellant’s entitlement to the related input tax credits is dependent on the outcome of this appeal. [7] [18] I have not been able to reconcile the Appellant’s and the Respondent’s numbers with respect to the amount at issue. ...

The Court considered that it was too late after the CRA audit for the payments to be recognized as shareholder loan repayments or payments for services rendered. ...

Subparagraph 254(2)(g)(i) provides, in part, that: the first individual to occupy the complex or unit as a place of residence at any time after substantial completion of the construction or renovation is (A) in the case of a single unit residential complex, the particular individual or a relation of the particular individual, and… [Emphasis added.] [12] This Court has considered eligibility for the GST/HST new housing rebate a number of times and those cases make it clear that eligibility for the rebate turns very much on the facts of the particular situation. ...

Section 147 of the Rules clearly grants a very broadly discretionary jurisdiction to the Court in the exercise of its power to determine: (1) the amount of the costs of all parties; (2) the allocation of those costs; and (3) the persons required to pay them. [13] [36] The Respondent has asserted that all “substantive issues” in dispute in the tax appeals were settled when the Respondent consented to suffer Judgments “in full”. [14] If that is so, it can only be inferred that the Respondent admitted “in full” the facts contained in the Appellants’ pleadings. [37] While the Respondent’s counsel asserts that the Kirzner Affidavit is flawed in some manner because particulars of an alleged sham, of which no evidence exists, were not considered, the Respondent continues to offer no evidence of any kind to support such allegations of impropriety. ...

According to Côté, supra, an interpretation can be considered absurd if it leads to ridiculous or frivolous consequences, if it is extremely unreasonable or inequitable, if it is illogical or incoherent, or if it is incompatible with other provisions or with the object of the legislative enactment (at pp. 378-80). ...

. […] […] [7] The main dispute between the parties regarding these steps is whether the taxpayer’s credibility is to be considered at Step 1 or Step 2. ...