- Parties: The appellant was the Canadian Western Trust Company as Trustee of the Fareed Ahamed TFSA. The respondent was His Majesty the King.

- Subject Matter: The appellant appealed reassessments for the 2009–12 taxation years. On appeal, the issue was whether tax was payable by a TFSA trust on income from carrying on a business of trading in qualified investments. The Tax Court dismissed the appeals and concluded that income earned by a TFSA trust from carrying on any business, including a business involving only qualified investments, was taxable under s. 146.2(6) of the Income Tax Act, 1985.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal with costs. The appeal court held that the Tax Court conducted a detailed textual, contextual, and purposive analysis. The appeal court determined that the appellant’s reading was unsupported by the text, context, and purpose of s. 146.2(6) and would amount to zre-drafting of the provision. The appeal court found no error in the Tax Court’s refusal to override the clear language of s. 146.2(6) based on purported policies transplanted from a different statutory regime and in the Tax Court’s statement that the TFSA regime aimed to allow Canadians to increase savings by earning tax-free investment income.

- Date: The hearing was set on June 11, 2024. The court released its decision on June 11, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: No financial award was specified.