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La Reine, 2007 DTC 1619, 2007 TCC 338 (Informal Procedure)-- summary under Specified Member Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Specified Member In finding that the taxpayer was a specified member of a partnership that had been formed only for the purposes of flowing R & D deductions out to investors and which had no significant activity, Archambault J. noted (at para. 38): "In my view, it is completely contrary to the intent of the Act to argue that one possible reason for Mr. ...

The taxpayer did not change his life pattern with respect to his continuous employment and social connections in Taiwan (including caring for his parents there and spending over ¾ of his time there); and Mogan TCJ accepted the taxpayer's explanation that the Regina connection had been established in order to have his children educated in North America. ...

The Court affirmed the finding of the trial judge that (p. 1212): "... the appellant, having only an option on shares, did not carry out its plan to make Poitras a subsidiary. ...

The Queen, 94 DTC 6620, [1994] 2 CTC 345 (FCTD)-- summary under Agency Summary Under Tax Topics- General Concepts- Agency shareholder generally does not carry on business of corporation Before finding, on the evidence, that the taxpayer had transferred all the assets of his chicken farm business to a corporation other than the land and the chicken quota and that the corporation was not an agent of the taxpayer, Wetson J. stated (p. 6622): "... one must start from the presumption that generally when a company is incorporated to carry on a business, the business becomes that of the company and the shareholder cannot claim that business as his or her own. ...

The Queen, 94 DTC 6620, [1994] 2 CTC 345 (FCTD)-- summary under Personality Summary Under Tax Topics- General Concepts- Personality Before finding, on the evidence, that the taxpayer had transferred all the assets of his chicken farm business to a corporation other than the land and the chicken quota and that the corporation was not an agent of the taxpayer, Wetson J. stated (p.6622): "... one must start from the presumption that generally when a company is incorporated to carry on a business, the business becomes that of the company and the shareholder cannot claim that business as his or her own. ...

The Queen, 94 DTC 6620, [1994] 2 CTC 345 (FCTD)-- summary under Separate Existence Summary Under Tax Topics- General Concepts- Separate Existence Before finding, on the evidence, that the taxpayer had transferred all the assets of his chicken farm business to a corporation other than the land and the chicken quota and that the corporation was not an agent of the taxpayer, Wetson J. stated (p. 6622): "... one must start from the presumption that generally when a company is incorporated to carry on a business, the business becomes that of the company and the shareholder cannot claim that business as his or her own. ...

. … …In addition, the supply of the consultation is a useful service even if a supply of a vaccine is not made.: ...

Profit- Leases and Licences In finding that gains from the sale of timber limits were realized on income account by the taxpayer, which had acquired the timber limits approximately ten years previously and had not provided any evidence that it had carried on logging operatons, Duff J. stated (p. 1214): "... ...

. … The only unusual aspect of the subleases in this case is that the tenants have access to a nine-hole golf course. ...

The Queen, 2005 DTC 384, 2005 TCC 167 (Informal Procedure)-- summary under Subsection 18(12) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(12) In finding that the principal place of business for the taxpayers, who carried on through a partnership a fishing business using two boats owned by them, was the work space in their home, Miller J. stated (at pp. 386-387): "... ...