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Liebig & Co. v Leading Investments Ltd., [1986] 1 S.C.R. 70, "the primary meaning of sale is the transfer of property to another for a price. ...

CRA responded: Innovative … [dealt with] a group creditor life insurance policy and not an individual life insurance policy. ...

. … Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...

Canadian Western and Natural Gas, Light, Heat & Power Co. in concluding that the word "similar" meant "of the same general nature or character", and went on to indicate that in the past it had regarded the following properties or services to be similar: (a) system software and applications software; (b) trucking of sand and gravel, and trucking of poultry and lumber; (c) mining and sale of metallurgical coal, and mining and sale of other minerals; (d) operating a hotel which includes a restaurant and lounge, and operating a restaurant and lounge; (e) operating a hotel or motel with no restaurant, operating a restaurant, and operating a hotel or motel with a beverage room but no separate restaurant, and operating a hotel with a restaurant; (f) operating a prime rib restaurant and operating a steak restaurant even where the latter is operated in conjunction with a hotel; (g) the sale of fast-food chicken and the sale of fast-food fish; (h) staging musical concerts in a stadium, and staging professional football; (i) security equipment, and electro-magnetic labels developed for use in libraries, hospitals and retail establishments; and (j) the manufacture of parts and major components for aircraft, and the design, manufacture and sale of aircraft. ...

18 December 2000 External T.I. 2000-0050255- CHANGE IN TERMS OF DEBT OBLIGATION-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition disposition if implied rescission due to fundamental change going to root of contract In response to a general question as to " whether a change in the terms of a debt obligation would result in a disposition of the existing obligation and the substitution of a new obligation in its place," CRA stated: "If, in accordance with the relevant contract law in Quebec, the changes in the terms of the original debt obligation have resulted in a novation (where the original debt obligation is discharged and substituted by a new obligation), it is appropriate to view the original obligation as having been disposed of for income tax purposes. ...

George Thompson & Company, Limited (1927), 13 TC 83 (Eng. KB) (“Scales”) sets out the test for the determination of whether certain operations are a separate business. ...

. … There is a logical connection between the income from ULC and the U.S. taxes paid by Taxpayer because if Taxpayer did not own such shares, no U.S. taxes would have been paid [citing Smidth]. ...

. … While we have considered the application of subsection 245(2) in respect of the Neuman type income splitting arrangements in the past and have taken the position that GAAR does not apply, we have also specifically stated that this comment regarding the non-application of GAAR relates only to the Neuman case. ...

Canadian Western Natural Gas, Light, Heat & Power Co. ((1922) 69 DLR 401 (Alta SC (AD)). ...

With a view to accessing s. 164(6), the executors retract the Class B shares – but before this occurs, Corporation redeems the Class C voting shares which, in turn, causes the Class B shares to become voting pursuant to s. 48(2) of the Quebec Business Corporations Act (a provision which effectively deems all shares to become voting whenever none otherwise has voting rights). ...