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In Ransom v MNR, [1967] CTC 346; 67 DTC 5235, Noël, J said this with reference to paragraph 6(l)(b) of the Act — it was paragraph 5(l)(b) at the time relevant to the Ransom decision — at page 359 [5243]: A reimbursement of an expense actually incurred in the course of the employment or of a loss actually incurred in the course of the employment is not an “allowance” within the meaning of the word in section 5(l)(b) as an allowance implies an amount paid in respect of some possible expense without any obligation to account. ...

Avery Jones, “Nothing Either Good or Bad, But Thinking Makes It So — The Mental Element in Anti-Avoidance Legislation” (1983) British Tax Review 9. ... More is to be gained by examining the second of the two requirements — reasonable expectation of profit. ... R., [1996] 1 S.C.R. 305, [1996] 1 C.T.C. 290, 96 D.T.C. 6121 at page 316 (C.T.C. 298, D.T.C. 6125); see also Dickson C.J. in Bronfman Trust, supra, at page 45 (C.T.C. 124, D.T.C. 5064). 9 See also Herald & Weekly Times Ltd., Re (Herald & Weekly Times Ltd. v. ...

The only difference between the 1991 version of subsection 80(4) and the transitional 1991 version is that the word "deducted" is employed in the latter version rather than the word “ deductible” after the words “ equal to the portion of the amount of such interest that was” appearing in the closing portion of these two versions. ...

According to Schedule 1 attached to the notice of assessment, that figure was arrived at as follows: Sale of land $2,307,330.00 Cost of land in 1960 $393,666.00 Capitalized carrying charges — 1960 to 1972 148,257.00 $ 541,923.00 1972 taxable income $1,765,407.00 Counsel for the plaintiff took two broad positions: (1) that the plaintiff’s dealing with the realty was not an adventure in the nature of trade, the submission being that it was acquired as an investment which resulted in a capital gain; (2) that the plaintiff was neither a resident of Canada nor a nonresident which carried on business in Canada and so was not taxable. ...

The evidence in this regard shows that Miracle Mart had never conducted such transactions before signing the “ licence agreement" with Geneseo. ... Now, how is the licence fee established; how did you come to establish a licence fee of six million dollars (6 000 000 $) for the sale of the business? ... What do you mean by “ traffic count"? A. That is the number of people walking through the store and making purchases. ...

Masny advised that “a visit be paid to the licensee to establish a combined Freight & Installation rate for their window coverings...” and he provided Ms. ... In Canada (Director of Investigation & Research, Combines Investigation Branch) v. ... T.D.). 19 (1983), 145 D.L.R. (3d) 385 (S.C.C.). 20 /</. at p. 400. 21 'The plaintiffs refer to the 1985 version of the Excise Tax Act, R.S.C. 1985, c. ...

She told him that she knew a Marc Levert, who acquired works of art at auctions and resold them at a low price — about 25 percent of their value. ... Lagueux & Frères Inc. (1974), 74 D.T.C. 6569 (Fed. T.D.), in which it was held that to determine the tax consequences of a transaction, the nature of the transaction must be determined under the civil law. ... Duguay [TRANSLATION] “was guilty of gross negligence, or even wilful blindness, in continuing year after year, for five years, to enter into the same kind of simultaneous transaction — paying 25 percent in exchange for a tax receipt, no matter what organization and property were involved — and in not wanting to see, in the case of Mr. ...

l î J j ', 8 y year after receiving his notice of assessment, the defendant applied for an extension of time for objecting to the assessment. ... The taxpayer, of course, must be in a position when he reads the notice of assessment to know — or to be capable of knowing — the date or dates the corporation failed to remit so that he may consider whether he was a director at the time of the failure by the corporation. ... Upon receipt of the notice of assessment, he knew that if ne did not agree with the assessment, he must object and appeal under the provisions of the Act — and he did so. ...

McLachlan’s law firm, McLachlan & Rissman, dealt on behalf of the RMM group with Mr. ... Richard Lipton of the Chicago law firm Sonnen- schein, Carlin, Nath & Rosenthal that provided initial tax advice to the RMM Group. ... The French version reads: Il est entendu que l’opération dont il est raisonnable de considérer qu’elle n’entraîne pas, directement ou indirectement, d’abus dans l’application des dispositions de la présente loi lue dans son ensemble — compte non tenu du présent article — n’est pas visée par le paragraphe (2). ...

Royalties — other than royalties to which article Ill ofthis Convention applies —— derived from one of the states by a resident of the other state shall be subject to tax only in the latter state. 2. ... In my opinion, a “made-for-T.V. movie" —— regardless of the media used — is a television program and not a motion picture film. ... There is, of course, the principle of statutory interpretation urged by the defendant that words of a statute be given a contemporary meaning consistent with section 10 of the Interpretation Act, supra, that “ he law shall be considered as always speaking”. ...