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. … She further found that the phrase "a right of any kind whatever" did not expand the ordinary meaning of "property" to include a non-exclusive, commonly held right to carry on a business, such as that held by the taxpayer. ...

. … This distinction means that under our Act it is only necessary to consider what the proceeds of the loan are to the borrower when they are received, and does not require an examination of what those loan proceeds are spent on. ...

Canada, 2018 FCA 121-- summary under Subsection 248(28) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(28) potential for double taxation under the ITA of NAL transactions The taxpayer, a Canadian exploration company, unsuccessfully argued that it was not subject to Part XII.6 tax on Canadian exploration expenses (“CEE”) that it had purported to renounce under the look-back rule- but which were now admittedly not eligible for look back because the flow-through share investors were non-arm’s length – because the reference in Part XII.6 to CEE that it “purported” to renounce under the rule referred only to expenses which had been validly rather than invalidly renounced under the look-back rule. ...

. … Despite his unusual lifestyle and his propensity to ridicule his opponents, the appellant was a serious businessman. ...

Regarding the Minister's argument that Article 13 was only included "for greater certainty," Sharlow J.A. stated: The OECD model conventions, including the Canada-Austria Income Tax Convention, generally have two purposes – the avoidance of double taxation and the prevention of fiscal evasion. ...

. … Grenon RRSP was obligated to file a return under Part I reporting taxable income. ...

In my view, the issue is not new …. However, even if it were a new issue, I am satisfied there is a sufficient basis in the record to resolve the issue and we have a duty to do so to ensure justice is done. ...

. … The Contracts mostly provide that the customer retained, on an exclusive basis, the services of IT 2005 SENC for the printing of their flyers and other advertising products in exchange for a price they committed to pay. ...

. … The same rationale applicable to income tax assessments must logically apply to CEWS determinations, namely, individual notices of determination may be appealed in a single notice of appeal without coalescing. ...

II, s. 1 – home care service. ...