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The respondent alleges in this case that the operations giving rise to the profits arose outside of Canada — specifically, the contract for the sale of the concentrate was negotiated in Lebanon and executed in the United States. ...

Abbott: As the hon. member will recall, this was the section which referred to the principal source of income, and then section 13(1) was introduced last year as a loophole section to cover what, for want of a better term, I shall call the hobby farmers — Mr. ...

.); FA & AB Ltd. v. Lupton (Inspector of Taxes), [1971] 3 All E.R. 948 (H.L.); Québec (Deputy Minister of Revenue) v. ...

Marsh & McLennan, Ltd., [1984] F.C. 609; [1983] C.T.C. 231; 83 D.T.C. 5180 at 244 (D.T.C. 5191; F.C. 627), Clément, D.J.; Golden v. ...

The final question is simply this — whether the words of paragraph 85(1)(e) of the Income Tax Act interpreted in their plain, ordinary and grammatical sense in context of the statutory scheme of section 85B reach out to bring within the tax net in 1969 the unearned premium reserve of $10,454,396 deducted in 1968. ...

Counsel for the respondent put great emphasis on the statements which appear in Article IV F of the plan to the effect that the employer's contribution is "on behalf of and as an absolute benefit for (the) member" and that such contribution ” shall be regarded as additional compensation paid to (the member)"; they likewise attach much importance to the fact that income taxes for participating employees are withheld not only from their wages but also from the employer's contribution. ...

.: — This is an appeal from a judgment of the Trial Division allowing in part the respondent’s appeal from the reassessment of its income tax for the 1978 taxation year. ...

.: — I have had the advantage of reading the reasons for judgment prepared by my brother Urie, J.A. ...

., as he then was, in London & Thames Haven Oil Wharves Ltd. v. Attwool (1966), 43 T.C. 491, at page 515: The question whether a sum of money received by a trader ought to be taken into account in computing the profits of gains arising in any year from his trade is one which ought to be susceptible of solution by applying rational criteria. ...

The precise scope of the residual category- windfall gains — has proven problematic. ...