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The Queen, 2008 DTC 2591, 2008 TCC 58-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) 50% shareholder was entitled to one of two directors with tie-breaking vote The taxpayer was subject to the de facto control of the holder of ½ of its shares ("Bost") given that under the unanimous shareholder agreement between BOST and the other 50% shareholder (the "USA"), the board was to consist of one director nominated by each shareholder, a nominee of Bost was to be the Chairman, and in the event of a tie of votes, the Chairman was entitled to cast the deciding vote. ...

. … Moreover, if the inn as a whole is the "work space" that work space is "the individual's principal place of business". ...

., the taxpayer disposed of "a right to a right" of the sort described in what then was s. 66(15)(c)(ii)(B) when under a "farmout agreement" with Esso Resources Canada Limited, the taxpayer received from Esso the sum of $4.5 million in consideration for "... the right, licence and privilege of earning an interest in oil sands rights... ...

See summary under s. 12(11) – investment contract. ...

See summary under s. 12(11) – investment contract. ...

See summaries under s. 232(1) – solicitor-client privilege and Tax Court Rule 82(2). ...

See summaries under s. 232(1) – solicitor-client privilege and Tax Court Rule 82(2). ...

See summaries under s. 232(1) – solicitor-client privilege and Tax Court Rule 82(2). ...

Rip J found that in these circumstances it was sufficient for her to hand a written resignation to the lawyer who had acted for the company, even though he never got around to filing the resignation in the minute book (or notifying the company's branch of the resignation, as required) – so that from the time of giving him the resignation, the two year period for barring CRA from making a derivative assessment under ITA s. 227.1(4) and ETA s. 323(5) started running. ...

. … Further, the appellant’s agent did not assert that two differing versions of the Act required reconciliation under subsection 31(2) of the LRCA. ...