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. … For someone other than CTM to service the mortgages would, as a practical matter, be commercially infeasible and would be inimical to the raison d'être of the transaction. ...

La Reine, 2007 DTC 1619, 2007 TCC 338 (Informal Procedure)-- summary under Specified Member Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Specified Member In finding that the taxpayer was a specified member of a partnership that had been formed only for the purposes of flowing R & D deductions out to investors and which had no significant activity, Archambault J. noted (at para. 38): "In my view, it is completely contrary to the intent of the Act to argue that one possible reason for Mr. ...

The taxpayer did not change his life pattern with respect to his continuous employment and social connections in Taiwan (including caring for his parents there and spending over ¾ of his time there); and Mogan TCJ accepted the taxpayer's explanation that the Regina connection had been established in order to have his children educated in North America. ...

. … …In addition, the supply of the consultation is a useful service even if a supply of a vaccine is not made.: ...

The Queen, 2005 DTC 384, 2005 TCC 167 (Informal Procedure)-- summary under Subsection 18(12) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(12) In finding that the principal place of business for the taxpayers, who carried on through a partnership a fishing business using two boats owned by them, was the work space in their home, Miller J. stated (at pp. 386-387): "... ...

Minister of National Revenue, 91 DTC 653, [1991] 1 CTC 2413 (TCC)-- summary under Paragraph 20(1)(bb) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) In finding subscription fees for various investment publications to be non-deductible, Dussault TCJ. stated (p. 655): "General subscription fees for an investment publication listing and analyzing hundreds and thousands of corporations and securities is not, in my view paying 'an amount to a person for advice as to the advisability of purchasing or selling a specific share or security of the taxpayer '. ...

The Queen, 94 DTC 1947, [1994] 2 CTC 2021 (TCC)-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs In finding that the expenses of various categories of work done on a vessel before the vessel sank and before the taxpayer acquired title to it, were deductible except to the extent that they were capital expenditures, Bowman T.C.J. stated (p. 1949): "... ...

Miller J. stated (at p. 3554): "... Paragraph 8(1)(i) does not stipulate that an assistant must be 'required by the contract of employment', but that the payment of salary to an assistant was required by the contract of employment. ...

Lamarre Proulx J. stated (p. 1385): "... The words 'property acquired' must be taken to mean property in which the taxpayer has a right of ownership, or if not such a right, then all the attributes of a right of ownership, as in the case of a conditional sale. ...

The Queen, 94 DTC 1894, [1995] 1 CTC 2163 (TCC)-- summary under Subsection 216(4) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(4) s. 216 does not relieve payor of liability In response to a submission that s. 216(4) seems to assume that a Canadian agent of a non-resident will receive rents or royalties on behalf of the non-resident free of withholding tax, Mogan TCJ. stated (p. 1898) that: "... if the Canadian agent is required to pay certain expenses and, his non-resident principal exercises the option in section 216 to pay Part I tax, there is nothing in section 216 which relieves the initial Canadian payor of his obligation to withhold and remit under subsection 215(1). ...