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See summary under General Concepts – Sham. ...

The Queen, 2008 DTC 2591, 2008 TCC 58-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) 50% shareholder was entitled to one of two directors with tie-breaking vote The taxpayer was subject to the de facto control of the holder of ½ of its shares ("Bost") given that under the unanimous shareholder agreement between BOST and the other 50% shareholder (the "USA"), the board was to consist of one director nominated by each shareholder, a nominee of Bost was to be the Chairman, and in the event of a tie of votes, the Chairman was entitled to cast the deciding vote. ...

. … Moreover, if the inn as a whole is the "work space" that work space is "the individual's principal place of business". ...

…[A]ll the three contracts are for three different purposes – for charter of accommodation barge, for use of barge in domestic are [sic] and for replacement decks. ...

. … In my view, the interpretation of the contracts that is more consistent with the language of the contracts and the undisputed facts is that [such] payments were consideration paid by Amex to Costco, either for Costco entering into the Co-Branding Agreement, or specifically for the exclusivity provision. ...

" See summary under General Concepts – Rectification and Rescission. ...

. … [T]he oral sublease between the plaintiffs and [the corporation] eliminates any element of doubt that the net effect of the whole transaction was to transfer the head lease and the gallonage payment rentals to the corporation, notwithstanding that there was not express formal assignment of the head lease itself. ...

" See summary under Treaties – Art. 9. ...

. … As a matter of law it does not follow that, because the solicitor-client relationship is generally one of agency, all financial obligations incurred by a lawyer while providing legal services are incurred as agent of its clients. ...

Before reaching this conclusion, Joyal J. stated (p. 6282) that: "... although a profit, expressed in percentage terms as a return on investment, on energy and time and effort expended, might not be of a nature to invite a take-over bid..., the test of reasonableness is met if a profit has been realized. ...