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. … [T]he phrase “return of premium” may be an accurate description of the maximum amount received by the Appellant upon the expiry of the term but it is misleading for the following reason. ... What the insurer paid as a benefit upon the expiry of the term was not, in a business sense or in an income tax sense, any part of the premiums for life insurance. … It was part of the insurer’s earnings. ...

. … The use of specific examples after a general term in legislation does not restrict the meaning of the general term to cases similar to the specific examples. ... Katsikonouris, [1990] 2 S.C.R. 1029 …. See summaries under Sched. V, Pt. ...

Richards was not a “particular individual”, stating (at paras. 16, 17 & 19): [S. 254(2)(a)] requires the builder to make a supply by sale to Ms. Richards in order for her to be a particular individual. … Ms. Richards not only believed that she had acquired no interest in the subject unit, but…at law, she had no beneficial interest… [T]he only supply made by the builder was the supply made pursuant to the original agreement. ...

., “more than 50% of their value” (para. 120)) from portfolio investments, Lamarre ACJ stated (at paras. 101-103): [T]he ordinary commercial meaning of portfolio investment in the international investment context is an investment in which the investor … is not able to exercise significant control or influence over the property invested in.... [T]he definition suggests thresholds ranging from 10% to 25% ownership … [although] a small group of well-organized investors could have a controlling interest while having less than 10% ownership…. ...

. … The legislator, in enacting subsection 69(11) and 110.6(7) of the Act, had no intention of neutralizing the effect of subsection 74.2(1) in circumstances such as these. … In the context of the attribution rules, the purpose of the [s. 73] election is to permit a taxpayer to defer or not the realization of a gain, and not to permit a taxpayer to avoid attribution. ...

The benefit is …. 10% of construction costs of $259,293 or, $25,929. This is clearly an advantage not available to regular customers and only available to Mr. ... However, in finding that the Jaques did not for the most part receive shareholder benefits in connection with the Furnishings, he stated (at para. 38): … Park Haven's sole purpose in acquiring most of the Furnishings was not to bestow any benefit on the shareholders, but to furnish a show home so as to enhance the saleability of custom homes in the area. ...

. … The [wife and children] acquired the shares from the Appellant for a purchase price of $0.01 per share and immediately thereafter sold them for a cash purchase price of $8,645 per share. ... If the minimum EBITDA Target set out in the SPA was not met, the Appellant’s wife and daughters were still entitled to retain the full cash purchase price that they received. … [T]he price agreed to by the Appellant’s wife and two daughters on the one hand, and Dental Corporation on the other, satisfies the definition of the term “fair market value”, which is understood to mean “the highest price an asset might reasonably be expected to bring if sold by the owner in the normal method... in a market not exposed to any undue stresses and composed of willing buyers and sellers dealing at arm’s length and under no compulsion to buy or sell”. ...

Hogan J stated (at para 25): … In Aridi, I held that an accountant’s neglect or carelessness in preparing a tax return is not sufficient in and of itself to allow the Minister to reassess beyond the Normal Reassessment Period. ... Hogan J dismissed the appeal, finding (at para 31): When a taxpayer hires an accountant to prepare his tax return and is aware that tax planning involving a deferral strategy … is being used to secure a tax advantage for the taxpayer’s benefit, a minimum degree of attention to or oversight over the accountant’s work must be exercised by the taxpayer. ...

The Queen, 2018 TCC 48-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation corp qualified as SBC where only business activity was unsuccessful efforts to sell its stock of equipment The market for the business of a corporation (“Radio Progressive “) of the taxpayer (Mr. ... Hébert from his disposition of its shares in August 2011 qualified as a business investment loss, Ouimet J stated (at paras. 19-22, TaxInterpretation translation): [19] In this case, the Court is of the view that Radio Progressive was carrying on an active business during the 12 months preceding its dissolution, namely in the 2010 and 2011 taxation years, despite the fact that its activities were minimal. … [20] Essentially, based on the evidence, Radio Progressive remained active in the years prior to its dissolution only in order to dispose of its stock of unsold radio communication equipment and parts. ...

Russell J further found that the taxpayer was not a de facto director, stating (at paras 38, 40): Jurisprudence reflects that the concept of de facto director should be limited to persons who hold themselves out as directors …. ... …[S]he engaged in no acts of management … let alone any actions specific to a director. ...