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As … noted in City of Calgary, such supplies are parts or components of the single overall supply of electricity. … To paraphrase [O.A. ... Regarding a submission that Bell Canada (at para. 131) that it “could have purchased the electricity from a retailer and the transmission and distribution services from a Local Distributor,” he stated (at para. 132) that the “Court must make its decision based upon the supplies actually made ….” ...

. … The idea that liability for capital tax would accrue in the relevant year regardless of when the tax was assessed… is consistent with the long established principle under the Income Tax Act that liability for tax arises not pursuant to the filing of a return or the issuing of an assessment or reassessment, but rather pursuant to the terms of the Income Tax Act itself [citing The Queen v. ... Riendeau ¸ 91 DTC 5416 (FCA); and subsection 152(3).] ...

MNR, 93 DTC 1473, [1993] 2 CTC 3148 (TCC)-- summary under Regulation 2902 Summary Under Tax Topics- Income Tax Regulations- Regulation 2902 The taxpayer unsuccessfully argued that interest expenses incurred by it to finance the payroll cost of its R & D personnel were not made for the purpose of generating expenses, not income, and therefore were not described in Regulation 2902(a)(c). ... " However, registration and travel costs arising from the attendance of R & D staff at computer software conferences were not denied by Regulation 2902(a)(F). ...

. … If we refer to the definition of that term in this same reference work, we read: Consideration provided by the person who receives a benefit in the synallagmatic contract; reciprocal benefit (perceived as equal) charged to a party to a contract, for example, wages in consideration for work, or the price in consideration for the article sold. ... … We see from reading the agreements.. that the common intention of the parties is that, if the premises are destroyed, disposed of or expropriated, the full amount of the grant, that is, $880,660, shall be reimbursed, prorated according to the number of years remaining. ...

. … It is clear that both the Annuitants and the Promoters intended the purchase price for the shares be the stated purchase price. … They misled the Applicant with respect to the value of the shares purchased by the RRSPs but this is not a "sham. ...

. … As noted in Sattva [2014 SCC 53], considering surrounding circumstances, as an interpretative aid, does not offend the parol evidence rule, which excludes evidence of the parties' subjective intentions and precludes considering evidence outside the words of the contract that would result in varying the contract in some manner. See detailed summary under ETA – s. 153(1). ...

. … The cost of a modification of the restrictions of the rights that a landowner has with respect to the use of land is a part of the cost of the land. …Density rights have to do with what the owner can do with the land. … It requires something of a leap of faith to claim capital cost allowance under Class 3 on a building that does not exist and may never exist. ...

Hershfield J found that the amended purchase agreement entailed, at most, a supply of a co-ownership interest in the property by the appellant to her friend in consideration for her friend’s guarantee – and did not result in any interest in the condo also being supplied by the builder to the friend (so that the new housing rebate was not denied to the appellant). ... Indeed, if such an agreement had been entered into to gain an unintended tax advantage, it might be seen as a wholly artificial transaction – a sham. ...

. … What it supplies is the agreement to use the Annual Resort Fees to fund its operations. … This…is the supply of something other than property. ...

Visser J noted (at para. 19) that “based on … Rizek, [2013 TCC 273] it is necessary to determine whether the dominant characteristic of the amount received by Mr. ... Russell through its accounts payable department, not through its payroll department, as it does not consider award recipients to be employees. … In contrast [to Rizek], Mr. ...