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LOCKE J.A.   Date: 20220426 Docket: A-318-20 Citation: 2022 FCA 70 CORAM: WEBB J.A. ... As she noted in paragraph 208: … But, that discretion must be exercised on proper grounds before a correct assessment can be made. ... François Daigle Deputy Attorney General of Canada FOR THE APPELLANT EY Law LLP Toronto, Ontario FOR THE RESPONDENT   ...

REASONS FOR ORDER BY: WEBB J.A.   Date: 20210312 Docket: A-423-19 Citation: 2021 FCA 55 Present: WEBB J.A. ... Drouin Deputy Attorney General of Canada For The Respondent   ...

Canada (Minister of Employment & Immigration), [1986] 3 F.C. 189 (Fed. ...

. – notwithstanding paragraph (c), references to expenditures on or in respect of scientific research and experimental development shall not include (i) any capital expenditure made in respect of the acquisition of a building, other than a prescribed special-purpose building, including a leasehold interest therein, [2] According to the appellant's testimony, the hay dryer in question was a big, large, huge building. ...

Minister of National Revenue, [1996] 2 CTC 88, 96 DTC 6232 Décary J.A — The Minister of National Revenue has denied the appellant’s application for charitable tax status under sections 149.1 and 248(1) of the Income Tax Act in a decision-letter dated October 14, 1994. ...

Cork claimed the following amounts as deductions: 1974 1975 1976 Accounting, Legal $ 130.00 $ 100.00 $ 125.00 Automobile* 1,078.97 970.13 2,092.24 Business Tax, Fees, Licence 25.00 "nil" "nil" Fire & Liability Insurance* 33.00 33.00 33.00 Interest, Bank Charges 2.00 6.00 "nil" Postage, Stationery 87.50 122.15 75.79 Rent:* (/6 of total rent paid) 1,169.22 1,180.00 1,274.40 Telephone (business portion) 99.12 141.85 200.13 Subscriptions 26.00 "nil" "nil" Capital Cost Allowance "nil" 400.00 1,341.15 Travelling Expenses (other than automobile) "nil" "nil" 1,114.03 $2,650.81 $2,953.13 $6,255.74 *items under appeal The bulk of automobile expenses claimed was for driving to and from work sites. ... Robertson (Inspector of Taxes), [1952] 2 All E.R. 728 (C.A.), and argues that travel from home to work and return is not travel ”... while away from home in the course of carrying on... business” in the sense of paragraph 18(1)(h). ...

The Statutory Scheme The relevant sections of the Income Tax Act for the purposes of this appeal are: 149.(1) No tax is payable under this Part upon the taxable income of a person for a period when that person was (f) "registered charity" — a registered charity; 248.(1) Definitions — In this Act, "business" — "business" includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), an adventure or concern in the nature of trade but does not include an office or employment; "registered charity" — "registered charity" has the meaning assigned by subsection 110(8); 110.(8) Definitions — In this section, (c) "registered charity" — “registered charity" at any time means (i) a charitable organization, private foundation or public foundation, within the meanings assigned by subsection 149.1(1), that is resident in Canada and was either created or established in Canada, or (ii) a branch, section, parish, congregation or other division of an organization or foundation described in subparagraph (i), that is resident in Canada and was either created or established in Canada and that receives donations on its own behlaf, that has applied to the Minister in prescribed form for registration and that is at that time registered as a charitable organization, private foundation or public foundation. 149.1(1) Definitions — In this section, section 172 and Part V, (a) "charitable foundation" — "charitable foundation" means a corporation or trust constituted and operated exclusively for charitable purposes, no part of the income of which is payable to, or is otherwise available for, the personal benefit of any proprietor, member, shareholder, trustee or settlor thereof and that is not a charitable organization; [Emphasis added] (b) "charitable organization" — “charitable organization” means an organization, whether or not incorporated, (i) all the resources of which are devoted to charitable activities carried on by the organization itself, (ii) no part of the income of which is payable to, or is otherwise available for, the personal benefit of any proprietor, member, shareholder, trustee or settlor thereof, (iii) more than 50% of the directors, trustees, officers or like officials of which deal with each other and with each of the other directors, trustees, officers or officials at arm's length, and (iv) where it has been designated as a private foundation or public foundation pursuant to subsection 110(8.1) or (8.2) or has applied for registration under paragraph 110(8)(c) after February 15, 1984, not more than 50% of the capital of which has been contributed or otherwise paid in to the organization by one person or members of a group of persons who do not deal with each other at arm's length and, for the purpose of this subparagraph, a reference to any person or to members of a group does not include a reference to Her Majesty in right of Canada or a province, a municipality, another registered charity that is not a private foundation, or any club, society or association described in paragraph 149(l)(1); (f) "private foundation" — “private foundation" means a charitable foundation that is not a public foundation; (g) "public foundation" — “public foundation” means a charitable foundation which, (i) where the foundation has been registered after February 15, 1984 or designated as a private foundation or charitable organization pursuant to subsection 110(8.1) or (8.2), (A) more than 50% of the directors, trustees, officers or like officials deal with each other and with each of the other directors, trustees, officers or officials at arm's length, and (B) not more than 50% of the capital contributed or otherwise paid into the foundation has been so contributed or otherwise paid in by one person or members of a group of such persons who do not deal with each other at arm's length, or (ii) in any other case, (A) more than 50% of the directors or trustees deal with each other and with each of the other directors or trustees at arm's length, and (B) not more than 75% of the capital contributed or otherwise paid in by one person or by a group of persons who do not deal with each other at arms' length and, for the purpose of clause (i)(B), a reference to any person or to members of a group does not include a reference to Her Majesty in right of Canada or a province, a municipality, another registered charity that is not a private foundation, or any club, society or association described in paragraph 149(l)(1); [Emphasis added.] ... Issue A — Is the Appellant Operating Exclusively for Charitable Purposes At the outset, and in response to a question from the Court, counsel for the respondent agreed that the imposition of the appellant, a corporate entity, into the Association's fund raising activities is not a factor in the determination of the issues in this appeal. ... When can a business be said to be related to the objects of a charity: — When, in my view, there exists between the commercial activity in question, considered in itself, and the charitable objects of the charity such a relationship that it can be said that by engaging in the commercial activity in question the charity is, in effect, contributing to the realization of its charitable objects. ...

Retail Outlets — Includes: (a) Dealer Operated Service Stations — these facilities are either owned or leased by Chevron or by the dealer. ... (b) Self-Service Stations — these facilities are usually owned by Chevron and operated by a Chevron agent. ... (c) Cardlock/Keylock — these are unattended facilities making sales to approved customers. ...

He was also, since 1962, vice- president of Universal Alarms Ltd (“ Universal Alarms") of which he held 50 per cent of the shares. ... Wednesdays, in full, and the evenings of other days, he was on the properties, checking the cattle in the fields, the fencing, and ” going over the general operation with the farm manager". ... Whether a source of income is a taxpayer's “ chief source" of income is both a relative and objective test. ...

Barnabe was to transfer the assets-- Q And had- A — and Mr. Barnabe said yes. ... Mitsui & Co. (Canada) falls into this second category. In Mitsui & Co. ... Barnabe was to transfer the assets — Q And had — A — and Mr. Barnabe said yes. ...