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Body & Paint Shop" was not entitled to deduct capital cost allowance in respect of the cost of that right, Roland St-Onge stated (p. 204) that "the trade name of a firm is purely goodwill and cannot be construed as a depreciable asset". ...

MNR, 95 DTC 5416 (FCTD)-- summary under Paragraph 22(1)(b) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Privacy Act- Paragraph 22(1)(b) Explanations provided by the Minister such as "disclosure of this information would prejudice the integrity of the investigation and therefore be injurious to the enforcement of the Income Tax Act " were insufficient to establish that disclosure of information should not be made. ...

Tekmark Global Solutions LLC (2010), 38 SOT 7 (Mumbai ITAT)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 no services provided through seconded employees As a U.S. resident (" Tekmark") had provided personnel only to work under the control and supervision of a resident of India ("Lucent") and did not render any technical services to Lucent through these personnel, the deputation of such personnel did not create a services PE. ...

The Queen, 96 DTC 6040 (FCA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business In affirming the finding of the Toronto judge that a "gift" received by a practising solicitor in order induce him to act in connection with a Florida real estate project was income, Marceau J.A. stated (at p. 6041): "... ...

The Queen, 96 DTC 6040 (FCA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement gift rceeived in course of business In affirming the finding of the Toronto judge that a "gift" received by a practising solicitor in order induce him to act in connection with a Florida real estate project was income, Marceau J.A. stated (at p. 6041): "... ...

Mogan T.C.J. found that deduction of ¾ of these losses as allowable business investment losses was not precluded by s. 40(2)(g)(ii) in light of the decision in Business Art Inc. v. ...

.'s Claim [1927] BY Int'l L156, at 162: "'... The decisions of principle of the highest courts of most countries continue to hold that neither the shareholders nor their creditors have any right to the corporate assets other than to receive, during the existence of the company, a share of the profits, the distribution of which has been decided by a majority of the shareholders, and, after its winding-up, a proportional share of the assets'. ...

.'s Claim [1927] BY Int'l L156, at 162: "'... The decisions of principle of the highest courts of most countries continue to hold that neither the shareholders nor their creditors have any right to the corporate assets other than to receive, during the existence of the company, a share of the profits, the distribution of which has been decided by a majority of the shareholders, and, after its winding-up, a proportional share of the assets'. ...

In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...

In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...