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See summaries under s. 118.1 – total charitable gifts and s. 104(1). ...

") – earned management fees and rental fees from W.L. In 2003, the taxpayer lent $3.5 million to an arm's length supplier of specially prepared boards ("Interact") secured by patents held by Interact's principal ("Cable"). ...

") – earned management fees and rental fees from W.L. In 2003, the taxpayer lent $3.5 million to an arm's length supplier of specially prepared boards ("Interact") secured by patents held by Interact's principal ("Cable"). ...

. … Until such time as the contemplated transaction closed, it is arguable that Aviva could have carved up its rights to acquire the shares among other persons so that, at closing, it would acquire not more than 20 per cent of the target company. ...

. … [T]he context of the deeming provision suggests that it is intended to operate at the level of computation of income and taxable income, as do paragraphs 96(2.1)(c) and (d), and only after the taxpayer has computed his or her or its income or loss from business and property. ...

This is because the making of exempt supplies is excluded from the definition of “commercial activities” … Also, I find that the legal fees incurred by the Appellant in the course of litigation commenced in January 2011 have not been shown to have been related to or connected with any commercial activity carried on by the Appellant. ...

(the “Canadian Resort Point Purchasers” and “American Resort Point Purchasers,” respectively – who also thereupon became member of the Appellant, along with the Canadian and U.S. ...

. … [T]he Appellant, when selling its limited partnership interests in Atria LP and CEC LP to the subsidiaries of AIMCo, clearly took into account the transactions… that resulted in the packaging of the real property into limited partnerships and the bumping of the adjusted cost base with respect to such limited partnerships. ...

. … Parliament…made the positive decision to limit the application of subsection 69(11) to transfers to tax-exempt entities that occur within the three-year period [in s. 69(11).] ...

. … The [wife and children] acquired the shares from the Appellant for a purchase price of $0.01 per share and immediately thereafter sold them for a cash purchase price of $8,645 per share. ...