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The difference was explained in the following terms: [TRANSLATION] Q. [...] ...

., in conformity with Stubart, was careful to qualify the importance of a bona fide business purpose by stating that, although it "... is not determinative of the artificiality of the deduction”, it “is certainly relevant”. ...

. … The words “prevent” and “prévenir” mean the same: to stop an event from happening before it happens. ...

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. ...

Lord Denning in Hosegood v Hosegood (1950), 66 TLR 735 at 738, in a civil case, put it this way: When people say that a man must be taken to intend the natural consequences of his acts, they fall Into error: there is no “must” about #; it is only "may”. ...

Thereafter interest would be an even $5,000 per annum at 10% [1] *. The amount of $7,207.98 written off in 1968 had been set up as an asset and income tax paid on same in 1967 as it was not until 1968 that it was considered to be a bad debt. ...

In cross-examination, he said that to him this site represented “... a possible opportunity for a modest-sized site”. ...

On April 5, 1960 these two men entered into what is commonly known in the legal profession as “a buy-sell agreement”, whereby the survivor had the right but not the obligation to purchase the shares of the deceased. (! ...

In Sutton Lumber & Trading Co, Ltd v MNR, [1953] 2 S.C.R. 77; [1953] CTC 237; 53 DTC 1158 Locke, J said at page 83 [244, 1161]: The question to be decided is not as to what business or trade the company might have carried on under its memorandum, but rather what was in truth the business it did engage in.... ...

The only case which I have been able to find in which this section was discussed at all was in the Tax Appeal Board judgment in the case of Renown Steel & Services Limited v MNR, [1969] Tax ABC 678, which held that since subsection 39(6) is an exempting provision it must be strictly construed and as on the facts of the case the controller held the shares as a guarantor and not as a maker of a loan, he did not come within the provisions of subparagraph 39(6)(b)(i) so that the companies were held to be associated. ...