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The relevant section and regulations of the Act read as follows: 125.1(1) There may be deducted from the tax otherwise payable under this Part by a corporation for a taxation year an amount equal to the aggregate of (a) 9% of the lesser of (i) the amount, if any, by which the corporation's Canadian manufacturing and processing profits for the year exceed the least of the amounts determined under paragraphs 125(1)(a) to (d) in respect of the corporation for the year, and (ii) the amount, if any, by which the corporation's taxable income for the year exceeds the aggregate of (A) where the year ends after 1976, the lesser of the amounts determined under paragraphs 124(2)(a) and (b) in respect of the corporation for the year, (B) the least of the amounts determined under paragraphs 125(1)(a) to (d) in respect of the corporation for the year, (C) 2 times the aggregate of amounts deducted under subsection 126(2) from the tax for the year otherwise payable under this Part by the corporation, and (D) the amount, if any, by which the aggregate of the corporation's Canadian investment income for the year and its foreign investment income for the year (within the meanings assigned by subsection 129(4) exceeds the amount, if any, deductible under paragraph 111(1)(b) from the corporation's income for the year; and (b) 5% of the lesser of (i) the corporation's Canadian manufacturing and processing profits for the year, and (ii) the least of the amounts determined under paragraphs 125(1)(a) to (d) in respect of the corporation for the year; except that in applying this section for a taxation year after the 1973 taxation year, the reference in paragraph (a) to “9%” shall be read as a reference to “8%” for the 1974 taxation year, “7%” for the 1975 taxation year, and “6%” for the 1976 and subsequent taxation years. 125.1(3) In this section, (a) “Canadian manufacturing and processing profits” of a corporation for a taxation year means such portion of the aggregate of all amounts each of which is the income of the corporation for the year from an active business carried on in Canada as is determined under rules prescribed for that purpose by regulation made on the recommendation of the Minister of Finance to be applicable to the manufacturing or processing in Canada of goods for sale or lease; and (b) ‘manufacturing or processing’ does not include (i) farming or fishing, (ii) logging, (iii) construction, (iv) operating an oil or gas well, (v) extracting minerals from a mineral resource, (vi) processing, to the prime metal stage or its equivalent, ore from a mineral resource, (vii) producing industrial minerals, (viii) producing or processing electrical energy or steam, for sale, (ix) processing gas, if such gas is processed as part of the business of selling or distributing gas in the course of operating a public utility, or (x) any manufacturing or processing of goods for sale or lease, if, for any taxation year of a corporation in respect of which the expression is being applied, less than 10% of its gross revenue from all active businesses carried on in Canada was from (A) the selling or leasing of goods manufactured or processed in Canada by it, and (B) the manufacturing or processing in Canada of goods for sale or lease, other than goods for sale or lease by it. 5200. ... </p>] 16 It seems clear to me that subparagraph (x) is to be referred to if subparagraphs (i) to (ix) are inapplicable, as they obviously are in this case. 17 My interpretation of the meaning of subparagraph (x) is that, if less than 10% of the gross revenue of a taxpayer is “from the selling or leasing of goods manufactured or processed in Canada by it ” its profits do not fall within the definition of “Canadian manufacturing and processing profits” and therefore, by analogy, in order for its profits to come within that definition, more than 10% of its gross revenue must come from goods “manufactured or processed in Canada by it ”. ...

When the latter died, Les Presses could continue without difficulty since the shareholders of Les Presses in fact in the long run were the resource persons of the company. ... Heath & Sherwood Drilling Limited v MNR, [1971] Tax ABC 518; 71 DTC 338; 3. ... Thus, in the case at bar there are the same addresses, telephone number, employees, and the same resource person for the two years under appeal, and the latter is president of one company and husband and father of the shareholders of the other. ...

. — By an agreement dated July 4, 1969, the taxpayers as equal partners purchased Part of Lot 3, 4, and 5, Concession 2, in the Township of Hope, know as the Belmont Farm, comprising 215.244 acres more or less for the amount of $100,000 (the property). ... The cost of this preparation initially was in excess of $900. — Immediately after acquisition, the taxpayers began advertising the property as Belmont Park, a showmobile area. ... They had certain business experience of a generally similar nature, had the financial resources to do so, and had a good motive to leave the hotel business (including certain family illnesses appropriately not stressed by counsel for the appellants). ...

This was with the goodwill, of course, of — well, they couldn’t do anything about it anyway — of the firm. ... Professional subscriptions & dues 321.75 TOTAL $7,022.43 Add: Capital cost allowance © Total expenses (deduct from “Gross Income”) 7,022.43 Excess of income over expenses $ 3,470.29 3.08 Other details were given concerning each item. ... Technical Staff Management — With Branch Managers, ensure that adequate staff resources are being maintained to meet the current and future work load on projects. ...

Otherwise my circumstances were: The benefit that I realized when I acquired the shares in question (1977) was from a person resident in Canada but with operations almost (see Note 1 & 2 below) exclusively outside of Canada, source of income almost (notes 1 & 2 below) entirely outside of Canada for beneficial employment totally attributable to duties of office outside Canada. ... (e) For purposes of subparagraph (1)(a)(v) the aggregate determined under this paragraph in respect of the non-resident person is the aggregate of (i) Any remuneration in respect of an office or employment that was paid to him directly or indirectly by a person resident in Canada and was received by the non-resident person in the year (1977) Except to the extent that such remuneration was attributable to the duties of an office or employment performed by him anywhere outside Canada* and (...) ... Note 1 In 1973, (after my transfer from Canada), Cl Power acquired stock in Norcen Energy Resources Limited perhaps with the idea of a Canadian operation with a value of $3,276,000 in a total asset value of $250,077,000. ...

The purchase of the property itself nearly exhausted his financial resources, and the time he had available for the farm was early in the morning (before 7:30 am) and late at night (after 6:30 pm) and on weekends. ... The financial statements which produced the losses in question are reproduced: F L JOHNSON “REGISTERED ANGUS” FARM INCOME AND EXPENSE 1973 INCOME Rental $1,000 $ Tax Rebate 163 1,163 EXPENSES Cattle Purchases 1,894 Feed and Seed 195 Insurance 258 Repairs and Maintenance 71 Taxes 333 Mortgage Interest 2,124 Loan Interest 296 Utilities 133 Telephone 94 Casual Wages 1,450 Truck Expense Gas and Oil $240 Repair and Maintenance 223 Insurance and Licence 155 618 7,466 — NET LOSS BEFORE DEPRECIATION ($6,303) DEPRECIATION—House $ 657 —Buildings 1,223 —Truck 325 —Equipment 27 2,232 ($8,535) LESS: Personal Consumption 450 ($8,085) DEPRECIATION FRAME SCHEDULE EQUIPMENT LAND HOUSE BUILDINGS TRUCK BUS PORTION Addition—1973 $135 $45,213 $6,566 $12,225 $1,082 Depreciation 27 657 1,223 325 $108 $45,213 $5,909 $11,002 $ 757 F L JOHNSON “REGISTERED ANGUS” FARM INCOME AND EXPENSE 1974 INCOME Rent $1,000 Cattle 892 892 Tax Rebate 178 $ 2,070 EXPENSES Cattle Purchases 1,851 Pasture Rent 136 Veterinary Service 148 Feed and Seed 547 General Repair and Maintenance 492 Building Repairs 393 Small Tools and Supplies 199 Casual Labour 1,825 Mortgage Interest 3,844 Loan Interest 371 Utilities 321 Phone 187 Insurance and Taxes 320 Truck Expenses Gas and Oil $331 Repairs and Maintenance 489 Insurance and Licence 192 1,012 11,646 NET LOSS BEFORE DEPRECIATION ($ 9,576) DEPRECIATION—House 591 —Buildings 1,100 —Truck 227 —Equipment 82 2,000 ($11,576) LESS: Personal Consumption 325 ($11,251) DEPRECIATION FRAME SCHEDULE LAND EQUIPMENT HOUSE BUILDINGS TRUCK BUS PORTION BALANCE—Jan. 1, 1974 $45,213 $108 $5,909 $11,002 $757 Addition — 300 $408 Depreciation — 82 591 1,100 227 BALANCE $45,213 $326 $5,318 $ 9,902 $530 Contentions The appellant’s position was that he was entitled to all of the amounts claimed since he had entered the operation with every intention of making it a viable going concern. ...

I find it difficult to avoid a conclusion that Dr Barr’s orchard activity was no more than a pleasant diversion from his busy life as a medical practitioner, and that he would have continued to regard it as such had it not occasioned such a constant drain on his resources to keep it going. ... Medical practitioner’s automobile and telephone expenses — Farming losses. ... A statement filed as Exhibit R-2 discloses the treatment accorded the loss claimed as a deduction by Dr Todd to have been as follows: Claimed Allowed Disallowed Taxes and Water $ 394.06 Irrigation Water — Allow 100% of $50.00 $ 50.00 Taxes —Allow 25% of $344.06 $ 86.01 $ 258.05 Insurance (not crop insurance) 4.14 Disallow 100% Nil 4.14 Electricity 164.89 Disallow 100% Nil 164.89 Interest (on purchase of property) 1,473.31 Allow 25% 368.32 1,104.99 Simca Car Expenses and Capital Cost Allowance (Wife’s car) 341.02 Disallow 100% Nil 341.02 Dwelling Repairs & Depreciation 543.31 Disallow 100% Nil 543.31 Total Disallowance $2,416.40 Thus the total of $504.33 allowed was said to relate to wages and tree-removal costs and other matters directly related to the orchard, and bore a definite relation to the earning of such income as the orchard had been able to produce. ...

I see in one month in 1978 I had gone to the T.R.C., which is the Teacher’s Resource Centre, to attend a meeting with the Superintendent and other Principals in regards to the crafts development program in the Division. ... It would range between — that particular year it ranged between 5 and 11. ... Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in the present case are 8(1)(h), (j) and (2). ...

For the respondent: — During its period of ownership, Grantaun made no additions to the property, nor did it apply to have the property rezoned commercial or industrial. — During its period of ownership, Grantaun received gross rental income in the amount of $377 in respect of the property. ... (d) The carrying costs of the property itself before development were foreseen by her as manageable within either her own resources or from property-generated resources. ... On the second element referred to immediately above (other factors), the Board makes particular reference to the following: — The plans or projections for the use of the property were vaguest in the extreme. ...

The issue then resolves upon whether fees for membership in the Canadian Institute of Mining & Metallurgy in the sum of $35 are properly deductible from the appellant’s income. ... From 1970 to 1972 he was an employee of J C Sproule & Associates who were engineers specializing in geology and who were also geophysicists. ... In 1972 he opened his own consulting firm, Addie Consultant Ltd, in British Columbia and in 1974 he joined the Department of Mineral Resources where he is now employed as District Geologist. ...