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Indeed, where Parliament is successful and a taxpayer is induced to act in a certain manner by virtue of incentives prescribed in the legislation, it is at least arguable that the taxpayer was attracted to these incentives for the valid business purpose of reducing his cash outlay for taxes to conserve his resources for other business activities. ... & F. 85 at page 144 (U.K. H.L.):...the only rule for the construction of Acts of Parliament is, that they should be construed according to the intent of the Parliament which passed the Act. ...

Rather than treating directors as a homogenous group of professionals whose conduct is governed by a single, unchanging standard, that provision embraces a subjective element which takes into account the personal knowledge and background of the director, as well as his or her corporate circumstances in the form of, inter alia, the company’s organization, resources, customs and conduct. ... Robertson J.A. categorized the reported cases into two categories: those that deal with “inside directors” and those that deal with “outside directors” At page 263 (5416-17), he states: [...] it is difficult to deny that inside directors, meaning those involved in the day-to-day management of the company and who influence the conduct of its business affairs, will have the most difficulty in establishing the due diligence defence. ...

Gaudet explained that he worked from a list of hotels and restaurants he had prepared from his own resources and from consulting the Yellow Pages. ... In Thill’s view, “ You get good salesmen on commission, not by paying a salary”. ... Michael Bendall testified he is a manager of project resources and works in data collection systems for industry. ...

Burns, in 1992, to include certain amounts paid by them to Choice Learning Centre for Exceptional Children Society (Choice) as tuition in respect of their son, Jody Burns, on the basis the payments constituted- in the relevant year- an allowable medical expense within subsection 118.2(2) of the Income Tax Act (the " Act ") which could be used in computing income tax payable for the particular taxation year by virtue of being eligible for a medical expense tax credit pursuant to subsection 118.2(1) of the Act. [3] Counsel for the respondent advised the Minister had accepted that the amounts paid for tuition, as claimed, by one or other of the appellants in the relevant year, had been paid and the Minister admitted Choice was an educational institution. [4] The appellant, Janet Burns testified she resides in Vancouver, British Columbia and is a Barrister and Solicitor. ... Pinkus and upon being provided with information about gifted children and material pertaining to organizations and resources relating to parents of gifted children together with information concerning schools and academic options for Jody, the appellant and her husband, Robert Burns, decided their son should attend school at Choice. ... " Stedman's Medical Dictionary- 25th Edition (Williams & Wilkins) offers this definition: "handicap- A physical, mental, or emotional condition that interferes with an individual's normal functioning. ...

The total capital gains reported by members of Groupe Ledoux thus represents the sum of $535,605 [(3 x 100,001) + 80,001 + 155,601] and the auditor added this amount as actually being business income made by Mr. ... Ledoux had sufficient financial resources to purchase and hold this $2,850,000 property over the long term. ... — each trust received $100,100, Mr. Ledoux $80,100 and Douxel $2,955,700. ...

(b) The cash crop operation During 1980 and 1981 the farm was share cropped on a one-third two-thirds basis because the appellant lacked the resources and machinery to do it himself. ... The horse inventory was reflected as follows (the monetary values were provided by the appellant): As at January 1990 Item Value Value 2 mares (over 4 years old) $6,000 1 stud 5,000 2 geldings (over 4 years old) 2,000 2 yearlings 1,000 5 two-year-olds 3,000 1 pony (for family) $ 500 $17,500 In 1992 4 mares (values not itemized) 1 stud 3 aged geldings 2 yearlings 2 two-year-olds 3 foals 1 mare (for family) $20,500 As noted earlier, the plan was to have five good brood mares producing profitable sales of offspring. ... Even with lower interest rates in 1984 (10 A) and in 1985 f ^), Mr. Hoeft said he was unable to borrow to begin his feeder-cattle operation again. ...

Coopers & Lybrand (Amsterdam) were appointed auditors. Unsworth explained that managing directors were analogous to officers of a Canadian corporation while supervisory directors were likened to the "Canadian-style director". ... It read: (d) "active business” carried on by a corporation in a taxation year means the business of manufacturing or processing property for sale or lease, mining, operating an oil or gas well, prospecting, exploring or drilling for natural resources, construction, logging, farming, fishing, selling property as a principal, transportation or any other business carried on by the corporation other than a specified investment business or a non-qualifying business; Both specified investment business and non-qualifying business were also defined. ... In L & F Holdings Ltd. v. M.N.R., [1975] C.T.C. 2192; 75 D.T.C. 150 (T.R.B.), Roland St-Onge, Q.C. ...

There are two resources available for the provision of the necessities of life: income and time. ... Payne, “ The Dichotomy between Family Law and Family Crises on Marriage Breakdown” (1989), 20 R.G.D. 109 at pages 116-17. ... The intentional exclusion of property from section 7, and the substitution therefor of “ security of the person" has, in our estimation, a dual effect. ...

Subsection 31(1) falls under the auspices of “special cases" in Division B — Computation of Income. ... To complete the context within which the impugned provision appears in the ITA, section 11 is within Division C — Computation of Taxable Income of the legislation. ... The Queen, [1976] C.T.C. 611; 76 D.T.C. 6373 (F.C.A.); Bechthold Resources Limited (No. 1) v. ...

Collier & Sons Ltd. (hereinafter called Collier) for the early part of 1982 and the latter part of 1985, and with Grolier Ltd. ... Since the decision of the Federal Court of Appeal, there have been several decisions of the Trial Division which have followed Parsons, supra, namely Be- chthold Resources Ltd. v. ... Block Research & Development (1981) Corporation v. M.N.R., [1987] 1 C.T.C. 253, 87 D.T.C. 5137 and my own decision in the case of Gibbs v. ...