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In finding that the deemed dividend arising on the share redemption occurred as part of the series of transactions resulting in the disposition of the Greenstone shares to the ultimate purchaser, Bowie J. stated (at pp. 620-1): "... a change in the identity of the purchaser, where the intention to sell remained intact throughout and the hiatus is as short as this one, cannot divorce the share redemption from the subsequent sale of the Cox shares..... ...

In affirming this reassessment, Rip T.C.J. noted (at p. 2414) that "the words '... incurred in the performance of... employment' refer to automobile expenses incurred by the employee while providing services under the employment contract" and that a person could not be deemed to be "travelling in the course of the office or employment" unless the travel actually involved the performance of some service as compared to simply getting oneself to the place of work. ...

The taxpayers' argument was contradicted by the "authoritative obiter " in S.T.B. that s. 245(7) applied to third parties only. ...

Mogan TCJ. stated (p. 1899) that: "... when the initial Canadian payor knows that he is paying an agent resident in Canada acting on behalf of a non-resident principal... the initial Canadian payor and the agent are jointly liable under subsections (1), (3) and (6) of section 215. ...

Mogan TCJ. stated (p. 1899) that: "... when the initial Canadian payor knows that he is paying an agent resident in Canada acting on behalf of a non-resident principal... the initial Canadian payor and the agent are jointly liable under subsections (1), (3) and (6) of section 215. ...

The partnership used cash (derived in part from a third party who had subscribed for ¾ of the equity in the partnership) to subscribe for preferred shares of a sister company of the taxpayer ("Holdings"), with Holdings in turn using the proceeds to subscribe for preferred shares of holding companies ("Holdcos") for the various indirect individual shareholders of the taxpayer. ...

The partnership used cash (derived in part from a third party who had subscribed for ¾ of the equity in the partnership) to subscribe for preferred shares of a sister company of the taxpayer ("Holdings"), with Holdings in turn using the proceeds to subscribe for preferred shares of holding companies ("Holdcos") for the various indirect individual shareholders of the taxpayer. ...

The partnership used cash (derived in part from a third party who had subscribed for ¾ of the equity in the partnership) to subscribe for preferred shares of a sister company of the taxpayer ("Holdings"), with Holdings in turn using the proceeds to subscribe for preferred shares of holding companies ("Holdcos") for the various indirect individual shareholders of the taxpayer. ...

(a) of the definition of "commercial activity" – nor was there any evidence that the sale was connected to any existing commercial activity of NM (including any connection which could engage ss. 141.1(1)(a) and (2)(a).) ...

However, in my opinion, it more accurately reflects reality to say that Fiducie transferred 433 shares whose unit market value was $6,550, that the actual selling price of those shares was $2,836,423 (433 × $6550), an amount which, in fact, 404 obtained when it resold the shares to Keolis, and that the consideration given for this market value of $2,836,423 included two elements: a $2,602,637 promissory note, and 404's agreement to pay fees that Fiducie would have had to pay if 404 had not been interposed in the series of transactions carried out to sell the shares in question to Keolis. ...