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By Interpretation Bulletin IT-368 dated March 28, 1977 and entitled, “Corporate Distributions — Clearance Certificates” a wide application is given to subsections 159(2) and (3) by the Minister, Paragraphs 1, 2 and 3 of that Bulletin are those relevant in this matter. ...

In this connection Defendant refers to the judgment of the Court of Appeal in the as yet unreported case of The Clarkson Company Limited, the Receiver and Manager of the property and undertaking of Rapid Data Systems & Equipment Limited v Her Majesty The Queen, No A884-77 a judgment dated April 18, 1978, [1979] CTC 96. ...

The case therefore turns, as Addy, J put it in D P McLaws v The Queen, [1976] CTC 15 at 16: 76 DTC 6005 at 6006, “... entirely on the interpretation to be given to those facts and on the conclusions of fact to be drawn therefrom.. ...

.: — In 1978, François Prévost In (FPI) operated a real estate brokerage business in Québec. ...

On this see L Berman & Co Ltd v MNR, [1961] CTC 237; 61 DTC 1150, per Thorson, P at page 247 [1156]: There is no doubt in my mind that the appellant made the payments in question as a business person intending to continue in business would reasonably do and that consequently, they were made in accordance with the ordinary principles of commercial trading or well accepted principles of business practice and I am unable to find any ground in Section 12(1)(a) for their exclusion. ...

Lion Brewery Company Limited (1910), 5 T.C. 568 at 581: “ It is clear that it is not every expenditure which is made by a trader for the promotion of his trade, and which, in fact, contributes to the earning of profits, which is a permissible deduction from the estimate of profits for Income Tax purposes.” ...

That was the reasoning adopted by the Supreme Court of Canada in Steer, supra, and in Stewart & Morrison Ltd. v. ...

Abbott: As the hon. member will recall, this was the section which referred to the principal source of income, and then section 13(1) was introduced last year as a loophole section to cover what, for want of a better term, I shall call the hobby farmers — Mr. ...

.); FA & AB Ltd. v. Lupton (Inspector of Taxes), [1971] 3 All E.R. 948 (H.L.); Québec (Deputy Minister of Revenue) v. ...

This surely would include repeatable experiments in which the steps, the various changes made and the results are carefully noted. 1 lt reads: 194. (2) In this Act, the “Part VIII refund" of a corporation for a taxation year means an amount equal to the lesser of (a) the aggregate of (i) the amount, if any, by which the scientific research and experimental development tax credit of the corporation for the year exceeds the amount, if any, deducted by it under subsection 127.3(1) from its tax otherwise payable under Part I for the year, and (ii) such amount as the corporation may claim, not exceeding 50% of the amount, if any, by which (A) the aggregate of all expenditures made by it after April 19, 1983 and in the year or the immediately preceding taxation year each of which is an expenditure (other than an expenditure prescribed for the purposes of the definition “ qualified expenditure" in subsection 127(9) claimed under paragraph 37(1)(a) or (b) to the extent that such expenditure is specified by the corporation in its return of income under Part I for the year exceeds the aggregate of (B) the aggregate of all expenditures each of which is an expenditure made by it in the immediately preceding taxation year, to the extent that such expenditure was included in determining the aggregate under clause (A) and resulted in (I) a refund to it under this Part for the immediately precedingtaxa- tion year, (II) a deduction by it under subsection 37(1) for the immediately preceding taxation year, or (III) a deduction by it under subsection 127(5) for any taxation year, and (C) twice the portion of the aggregate of amounts each of which is an amount deducted by it in computing its income for the year or the immediately preceding taxation year under section 37.1 that can reason ably be considered to relate to expenditures that were included in determining the aggregate under clause (A); and (b) the refundable Part VIII tax on hand of the corporation at the end of the year. 2 information Circular 86-4R was issued on September 25, 1987. 3 As will be seen from what has already been said in relation to Professor Snelgrove's evidence, the three criteria referred to in paragraph 2.10 of 1C86-4R2 are the criterion of scientific or technological advancement, the criterion of technologi cal uncertainty and the criterion of scientific and technical content. ...