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., 2015 ONSC 7189-- summary under Paragraph 6204(1)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(1)- Paragraph 6204(1)(a) board had discretion to determine fixed liquidation entitlement In addition to denying the s. 110(1)(d) deduction on the basis that executives had sold their optioned shares to a specified person (who on-sold to the arm’s length purchaser of the corporation, namely, Rogers), rather than directly to Rogers, CRA also considered that the shares were not prescribed shares because the Board on liquidation had the discretion to establish a fixed liquidation amount for the shares. ...

These carrying charges can be considered as part of the cost of acquiring and disposing of the shares. ...

The court considered whether the covenant could be rectified on the basis that the term "Metropolitan City of Vancouver" mistakenly described the geographic scope of the covenant, and denied rectification because the parties did not have a prior oral agreement regarding the geographic scope of the covenant and the parties did not mistakenly describe something else in the written contract. ...

Noël CJ considered that premium amortization did not accord with mark-to-market accounting, and directed the Minister to reassess on the basis that the taxpayer was entitled to use the mark-to-market accounting, but without deferring or amortizing any portion of the premiums paid or received during 1998. ...

The Queen, 2016 TCC 252-- summary under Technical Notes Summary Under Tax Topics- Statutory Interpretation- Technical Notes Explanatory Notes not followed Lyons J applied the single supply doctrine to find that, as the University was making a single supply of education (a service) to its students, it should be considered to have acquired the books which it supplied to them at no additional charge for this “ultimate” purpose rather than for the purpose of merely transferring their ownership to the students. ...

The Queen, 2017 TCC 46 (Informal Procedure), rev'd in part 2018 FCA 110-- summary under Section 14 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Canada Pension Plan- Section 14 ITA s. 96(1.1) allocation of professional income was included A retired Deloitte partner received an opinion from his firm that professional income allocated to him under ITA s. 96(1.1) was a retiring allowance and thus excluded from being subject to CPP contributions, and also relied on the CRA opinion in 9527946 that: Income allocated pursuant to subsection 96(1.1)… for the purposes of the CPP provision is not considered to be from a business carried on by the retired partner and consequently such a partner is not required to contribute to CPP solely as result of receiving such income. ...

Scott JA considered this approach to be contrary to s. 261(2)(b), stating (at paras. 5-6): The taxable transactions in this appeal occurred when the appellant exercised his stock options…. ...

The Queen, 2017 TCC 188 (Informal Procedure)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date tax effect given to a retroactive court order Whether the taxpayer was able to take a deduction for a dependent child depended on whether in the year in question she was considered to have a support obligation to her ex-spouse. ...

Supreme Court for a declaration that a purchaser of the foreclosed properties would be considered to be acquiring them from the (resident) banks rather than from the non-residents (so that s. 116(5) would not apply.) ...

. … [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. ...