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Counsel for the respondent contended that the application of subsection 56(2) of the Act is supported by the following facts: (a) the dividend payment was not the product of a bona fide business relationship” (judgment of Dickson, C.J.C. at page 35), but was conceived as part of a tax avoidance plan; (b) the dividend payment was, in effect, a rerouting of monies from New- mac, in which the appellant's wife had no claim or entitlement, that would otherwise have been payable to the appellant; (c) the declaration of a dividend, although normally the function of a director, in this case was the fruit of the appellant's recommendations to his wife; (d) the declaration of the dividend to the appellant's wife from Melru was merely a temporary device for the redirection of the dividend, as the money was immediately lent back to the appellant by his wife on non-commercial terms; and (e) ”... there was no legitimate purpose to the dividend distribution” (judgment of Dickson, C.J. at page 35), within the meaning of the majority judgment in McClurg. ...

The Statute The relevant provisions of the Income Tax Act are found in Part I, Division I — Returns, Assessments, Payment and Appeals. ...

You are willing to gift approximately $100,000 worth of shares (after a proposed split — see below) in the company to Lance and Kevin in order to obtain maximum tax benefits on a total family unit basis. ...

Apart altogether from what has been said concerning the existence of a trust, if superior judicial authority did not cling so tenaciously to the doctrine of the absolute distinction of identity between a corporation and its shareholders as propounded over 85 years ago by the House of Lords in Salomon v Salomon & Co Ltd, [1897] AC 22, one might regard a single shareholder corporation like Enterprises in the light of its relationship to the appellant and conclude that in truth and substance what was attempted was to establish a trust under which the settlor, the trustee and the sole beneficiary are the same person, which is not permissible under the law of trusts. ...

. /. The assessment appears to obliterate the distinction between active and passive business which is prescribed in the Income Tax Act. 8. ...

Indian Head School Division 19 ® [30] in ascertaining the existence and extent of the duty of fairness owed to those affected by a decision, a strong argument can be made in this instance that the Applicant was entitled to state its views before the Minister could hold that its imports were no longer eligible for remission. ...

Exhibit A-l contained a number of documents relative to the operation in question and Exhibit A-2 was a summary of the profit and loss situation for M & K Stables from 1975 to 1992. ...

Johnston states that either on March 29 or March 30, he caused the three beneficiaries, (his wife & two children, who at the time were four and five years of age) to execute the elections. ...

Subsection 125(1) of the Income Tax Act reads as follows: Small Business Deduction 125. (1) There may be deducted from the tax otherwise payable under this Part for a taxation year by a corporation that was, throughout the year, a Canadian-controlled private corporation, an amount equal to 25% of the least of (a) the amount, if any, by which (i) the aggregate of all amounts each of which is the income of the corporation for the year from an active business carried on in Canada, exceeds (ii) the aggregate of all amounts each of which is a loss of the corporation for the year from an active business carried on in Canada, (b) the amount, if any, by which the corporation’s taxable income for the year exceeds the aggregate of (i) 10/4 of the aggregate of amounts deducted under subsection 126(1) from the tax for the year otherwise payable by it under this Part, and (ii) 2 times the aggregate of amounts deducted under subsection 126(2) from the tax for the year otherwise payable by it under this Part, (c) the corporation’s business limit for the year, and (d) the amount, if any, by which the corporation’s total business limit for the year exceeds its cumulative deduction account at the end of the immediately preceding taxation year, except that in applying this section for a taxation year after the 1972 taxation year, the reference in this subsection to “25%” shall be read as a reference to “24% for the 1973 taxation year, “23% for the 1974 taxation year, “22%’’ for the 1975 taxation year, and “21 %” for the 1976 and subsequent taxation years. ...

”’... Here is a full-time professor at Ottawa University, he spends 30 or 40 hours a week in the building, he has an office, he has a secretary, if you look him up in the Ottawa University phone book, his phone number is in there, he’s a member of the pension plan, a member of the faculty union. ...