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. … The most that can be said is that he intermittently stayed at the work site and did not even have the means of establishing a “residence” within the meaning of section 110.7 of the Act, even though that was his intention. ...

Following the realization shortly thereafter by Newco of a taxable capital gain and recapture of depreciation on a sale of the building, Newco increased the adjusted cost base to Holdco of its shares by effecting a series of s. 84(1) dividends (including a capital dividend) – following which the individual sold his shares of Holdco to a third party for a sale price based on the amount of cash sitting in Newco. ...

This arrangement appears to be more comprehensive than the one featured in Costco [2009 TCC 134] …. ...

…At its most basic level …, the benefit that Visa offered CIBC was cost saving and logistical simplification. ...

(t) of “financial service,” Rossiter CJ first found that the services of Visa were “quintessentially administrative in nature” so as to come within s. 4(2)(b) of the Regulation, and then rejected the suggestion that Visa was a broker, stating (at para 128): The definitions of a broker … give the impression of someone that actively engages in commercial activity, such as negotiating, buying and selling, on behalf of a principal. ...

. … Prior to SOCAN coming into existence, a music composer’s client paid the composer directly for the services rendered in writing and recording tracks/cues for television episodes. ...

In finding that the appellant did not satisfy the documentary requirements for claiming input tax credits, Favreau J stated (at paras. 58-59, TaxInterpretations translation): The appellant thus did not have in hand the particulars prescribed by the Regulation at the time that it claimed the ITCs as required by paragraph 169(4)(a) …. ...

(f) of the ECP definition for “the cost of … a right to acquire [a share]” did not apply, given that “the word ‘cost’ contemplates an acquisition of an asset or other property” (para. 103), whereas “when a stock option is surrendered to the issuing corporation, the rights represented by that option [instead] are extinguished” (para. 122). ...

In finding that its resulting foreign exchange gains and losses were realized under s. 95(2)(f) on income account, C Miller J stated (para. 276): The acquisition of the short term securities, taking their yield and funding a derivatives program to produce a greater yield is … using these short term securities in a manner akin to inventory in an income producing scheme. ...

. … [T]he remaining 90% of the cost of the trip, being $37.6 million, was the amount of the benefit conferred on and enjoyed by M. ...