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However, before concluding that “a snowmobile is … not a motor vehicle since it is not designed or equipped for use on public roads,” it stated: The first expression used, “designed or adapted” should, in our view, be used not in the sense of “capacity” but rather in the sense of “having or being organized for a specific use.” ...

However: [If] the non-resident student attending a university outside Canada ceased to be resident in Canada in a previous year, at or after leaving Canada, in order to attend that university … the student would be deemed, under paragraphs 115(2)(b) and (d), to have been employed in Canada during the year for the purposes of subsection 2(3). ...

. … In Mr. A's case, it is reasonable to assume that the assumption of responsibility for the mortgage debt obligations was intended to generate income by protecting his investment. ...

. … [S]ince the necessity to effect the circular calculation…is well known, we believe that a reasonable and prudent person would have effected the circular calculation in order to report (in the income tax return filed) the correct figures to the Minister. ...

. … Since a portion of the lump sum received in respect of the Medical Plan was received before 2012, that portion does not have to be included in the computation of the Objectors’ income. ...

" … [A] member of a non-profit organization can make a loan to a NPO without jeopardizing the status of the NPO, even if the member, as a creditor, receives interest on its debt to the extent that the interest rate on its claim is reasonable. ...

. … If, on the other hand, the CCA relates more to the business as a whole (i.e. related to reported income and undeclared income), we are of the view that it would not be wholly applicable to undeclared income and would not be allowed as a deduction for the purpose of calculating the penalty. ...

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. … [T]he Taxpayer would need to demonstrate that the ship owner is operating the ship under the Taxpayer’s direction and not, in effect, under the direction of the Related Party Customers. ...

. … The CRA's longstanding position is instead to reduce the safe income on hand by every dollar of expenses that contributed to the loss sustained by the corporation on the grounds that such income is no longer on hand to contribute to the unrealized capital gain on a share. ...