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") – 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"). ...

It was reasoned that the mere holding of inventory does not constitute a use of the property for an income-producing purpose in the context of considering a conversion of depreciable property to inventory (or vice versa) – whereas inventory should be considered to be income-producing property in the context of a conversion of personal-use property to inventory, or vice versa. ...

. … [I]f an item of property is not relevant to income in a particular year, it does not convert to capital property unless it meets the requirements of ss. 13(7) and 45(1). ...

Following a proposal by the Minister, over six months following the death of the taxpayer’s husband, to assess the taxpayer for trust income, she executed a form purporting to confirm that she had disclaimed her entitlement to income from the trust – and took the position that the distributions to her were of taxed capital. ...

Following a proposal by the Minister, over six months following the death of the taxpayer’s husband, to assess the taxpayer for trust income, she executed a form purporting to confirm that she had disclaimed her entitlement to income from the trust – and took the position that the distributions to her were of taxed capital. ...

Dussault J. found that the buy-back right represented an amount that "may reasonably be expected, having regard to statements and representations made in respect of the interest, to be received or enjoyed by a person (... 'the purchaser')... which receipt or enjoyment would have the effect of reducing the impact of any loss that the purchaser may sustain in respect of the interest" and found that the buy-back right could also be concluded to be more specifically referred to in Regulation 231(6)(c). ...

. … I am unable to see how the broad wording of the relevant provisions and the interpretation thereof by the Federal Court of Appeal that the wording is mandatory and should be strictly enforced, and which requires that the ITC claimant have the registration number assigned to the supplier, should result in any different outcome in this case ...

Repairs or Running Expense pension fund settlement was one-time expenditure for enduring benefit In finding that a lump sum paid by the taxpayer to establish a pension fund for the benefit of its employees was a non-deductible capital expenditure, Viscount Cave L.C. stated (pp. 213-214): "... ...

Sharlow JA stated (at para. 13): In my view, there has been in this case a transmission of the liability of the Taxpayer Trust to another person by "other means" – which I take to include the termination of the existence of the taxpayer. ...

Sharlow JA stated (at para. 13): In my view, there has been in this case a transmission of the liability of the Taxpayer Trust to another person by "other means" – which I take to include the termination of the existence of the taxpayer. ...