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In finding that s. 160 applied to the transactions in light inter alia of the cash proceeds received by Harvard Properties exceeding the FMV of the Newco shares sold by it, Boyle J found (at para. 166) that Harvard Properties had failed to establish any value for the shares, stating (at para. 174): There appears to be little to no chance that any arm’s length party unrelated to these transactions would agree to accept, much less pay for, the HP Newco shares at the relevant time as the Newcos would moments in time later have no assets, no business, and the possibility of a significant liability for their roles in these transactions …. ...

. – whereas here the taxpayers had substantiated the existence of an RCA by obtaining an actuarial report to support the amount of contributions necessary to provide them with a reasonable pension on retirement. ...

II, s. 1 – home care service. ...

Although the transactions entailed surplus stripping, "it is doubtful whether in an integrated corporate/shareholder tax system, a surplus strip per se can be said to abuse the spirit and object of the Act " (para. 101). ...

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

") – 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"). ...

") – 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"). ...

. … Until such time as the contemplated transaction closed, it is arguable that Aviva could have carved up its rights to acquire the shares among other persons so that, at closing, it would acquire not more than 20 per cent of the target company. ...

. … [T]he context of the deeming provision suggests that it is intended to operate at the level of computation of income and taxable income, as do paragraphs 96(2.1)(c) and (d), and only after the taxpayer has computed his or her or its income or loss from business and property. ...

This is because the making of exempt supplies is excluded from the definition of “commercial activities” … Also, I find that the legal fees incurred by the Appellant in the course of litigation commenced in January 2011 have not been shown to have been related to or connected with any commercial activity carried on by the Appellant. ...