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" Furthermore, PTAQ failed to establish "that it exercised monthly financial monitoring and control of expenditures… that it funded " (para. 48), and "the fundraising documents… indicated that VPT was conducting the fundraising activities on its own behalf" (para. 50). ...

(a) of the definition of "commercial activity" – nor was there any evidence that the sale was connected to any existing commercial activity of NM (including any connection which could engage ss. 141.1(1)(a) and (2)(a).) ...

However, in my opinion, it more accurately reflects reality to say that Fiducie transferred 433 shares whose unit market value was $6,550, that the actual selling price of those shares was $2,836,423 (433 × $6550), an amount which, in fact, 404 obtained when it resold the shares to Keolis, and that the consideration given for this market value of $2,836,423 included two elements: a $2,602,637 promissory note, and 404's agreement to pay fees that Fiducie would have had to pay if 404 had not been interposed in the series of transactions carried out to sell the shares in question to Keolis. ...

In rejecting the submission, and finding that the amounts were deductible to the taxpayer, Archambault, J. stated (at para. 22-23): "... ...

" … The fact that the limited partners may have had an ownership interest in the assets did not detract from the conclusion that the General Partner was a "purchaser" within the meaning of the Tax Act and was required to pay tax on the full amount of the purchase price allocated to the tangible personal property. ...

After noting (at p. 5016) that the issue was whether there was a “clear and unequivocal positive act” to implement a change of intention so as to “indicate a change in the character of the homestead property from a capital asset to a trading asset,” McNair J. held that a change in use from capital property to inventory did not occur until 1976, which was the year in which "the family held the first official meeting of shareholders to discuss what should be done with the … property" (p. 5014). ...

In finding that such payments by RBC were the consideration for a taxable supply by CAIL of Points, Hershfield J stated (at para. 28): Everything CAIL did from being involved in establishing the terms of the credit facility to advertising the program was to promote the use of the card by the issuance of Points and that is what it was paid for – the issuance of Points. ...

. … The facts that CU and CUH intended to use both the ATCOR/Forest transactions and the normal course dividends to achieve their tax avoidance objective, that they had the ability to ensure that all the transactions would occur, and that all the transactions did indeed occur as intended are sufficient to constitute them all part of a common law series for the purposes of subsection 55(2). ...

Although the U.S. dollars delivered under the contract appreciated significantly, Sir John Vinelott found (at p. 137) that: "... the agreement between the company and the bank was a single composite agreement under which the company could not deal with the forward contract without the consent of the bank and under which the bank was to be at liberty to use the dollars purchased in discharge of the dollar loan, to the extent that that had not been repaid before 15 March 1983. ...

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