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The process so far as then s 39 of the Income Tax Act was concerned was completed by Cattanach J in Vineland Quarries & Crushed Stone Ltd v Minister of National Revenue, [1966] CTC 69; 66 DTC 5092: “In my view the word 'controlled' in section 39(4)(b) contemplates and includes such a relationship as, in fact, brings about a control by virtue of majority voting power, no matter how that result is effected, that is, either directly or indirectly.” ...

The evidence is clear that the plaintiff did not extricate himself from the auto repair business in either 1978 or 1983, in part, because he could not afford to do so — the money made from employment in those businesses was being used by him to help establish his farm. ...

The bulk of judicial prose generated on the subject of fiscal residence has related to the peripatetic lifestyle of the leisurely wealthy — the jet setters of yesteryear. ...

Greenbaum (1957), 55 L.G.R. 129, he quotes: Anybody can apply for it — a member of the public who has been inconvenienced, or a particular party or person who has a particular grievance of his own. ...

Whether the “ without prejudice” qualification in the letter of January 26, 1982 would vitiate the arrangement as an agreement is a question I have not addressed. ...

Such arrangements as he did make for the receipt of mail during his absence from Canada between March 1988 and December 1989 broke down — but that, surely, cannot be laid at the feet of the Minister who acted throughout in the manner required by the Act. ...

.: — The plaintiff, Mr. Del Zotto, brings two motions. One is to amend the statement of claim pursuant to Rule 420. ...

Robertson had an arrangement with a law firm in Regina, Thauberger & Company, that where a client did not have a lawyer and wished to incorporate, they would use one of the Thauberger "shelf companies" to try to keep the costs manageable. ...

The word “ allowance” was defined in Ransom v. M.N.R., [1967] C.T.C. 346, 67 D.T.C. 5235, at page 361 (D.T.C. 5244) as follows: An allowance is quite a different thing from reimbursement. ...

Statutory provisions The relevant statutory provisions are subsections 66(6) and (7), 87(1), (2) and (6) of the Income Tax Act: 66(6) Where a corporation (in this subsection referred to as the “ successor corporation") has, at any time after 1971, acquired by purchase or otherwise (including an acquisition as a result of an amalgamation described in subsection 87(1), from another corporation (in this subsection referred to as the "predecessor corporation") all or substantially all of the property of the predecessor corporation used by it in carrying on in Canada its business, there may be deducted by the successor corporation, in computing its income under this Part for a taxation year, the lesser of.... 66(7) Where a corporation (in this subsection referred to as the "second successor corporation") has, at any time after 1971, acquired by purchase or otherwise (including an acquisition as a result of an amalgamation described in subsection 87(1)), from another corporation (in this subsection referred to as the "first successor corporation") that was a successor corporation within the meaning of subsection (6), all or substantially all of the property of the first successor corporation used by it in carrying on in Canada its business, there may be deducted by the second successor corporation, in computing its income under this Part for a taxation year, the lesser of.... 87(1) In this section, an amalgamation means a merger of two or more corporations each of which was, immediately before the merger, a Canadian corporation (each of which corporations is referred to in this section as a“ predecessor corporation") to form one corporate entity (in this section referred to as the "new corporation") in such a manner that (a) all of the property of the predecessor corporations immediately before the merger becomes property of the new corporation by virtue of the merger, (b) all of the liabilities of the predecessor corporations immediately before the merger become liabilities of the new corporation by virtue of the merger, and (c) all of the shareholders (except any predecessor corporation) of the predecessor corporations immediately before the merger become shareholders of the new corporation by virtue of the merger, otherwise than as a result of the acquisition of property of one corporation by another corporation, pursuant to the purchase of such property by the other corporation or as a result of the distribution of such property to the other corporation upon the winding-up of the corporation. 87(2) Where there has been an amalgamation of two or more corporations after 1971 the following rules apply: (a) for the purposes of this Act, the corporate entity formed as a result of the amalgamation shall be deemed to be a new corporation the first taxation year of which shall be deemed to have commenced at the time of the amalgamation, and a taxation year of a predecessor corporation that would otherwise have ended after the amalgamation shall be deemed to have ended immediately before the amalgamation; 87(6) Where there has been an amalgamation of two or more corporations after 1971 and the new corporation is a principal-business corporation within the meaning assigned by subsection 66(15), there may be deducted by the new corporation in computing its income for a taxation year the aggregate of the following amounts in respect of expenses incurred by the predecessor corporations, namely, in respect of each individual predecessor corporation, the amount that is the lesser of... ...