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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): "... ...

In finding that the U.S. corporation was associated with each Canadian corporation (with the result that each Canadian corporation was associated with the other two Canadian corporations under the pre-1972 version of s. 256(2)), Jackett C.J. noted (p. 5037) that the rules in s. 39(4) of the pre-1972 Act applied "for the purposes of this section", that those rules determined the amount of tax payable under Part I by associated corporations and that it followed "that section 39(4) has no application to determine whether two corporations are associated unless they are both subject to income tax under Part I of the Income Tax Act ". ...

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Minister of National Revenue, 91 DTC 653, [1991] 1 CTC 2413 (TCC)-- summary under Paragraph 20(1)(bb) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) In finding subscription fees for various investment publications to be non-deductible, Dussault TCJ. stated (p. 655): "General subscription fees for an investment publication listing and analyzing hundreds and thousands of corporations and securities is not, in my view paying 'an amount to a person for advice as to the advisability of purchasing or selling a specific share or security of the taxpayer '. ...

Canada, 99 DTC 5669, [1999] 3 S.C.R. 622, [1999] 4 CTC 313-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 s. 67 does not apply where provisions, having their own internal limiting clauses, apply In refusing to apply s. 67 to interest that was found to be reasonable in amount for purposes of the reasonableness limitation expressed in s. 20(1)(c), McLachlin J. stated (at p. 5678): "... it seems to me that Parliament intended s. 67 to apply primarily to those deductions claimed under the provisions of the Act that do not have their own internal limiting clauses.... ...

General Provisions general reasonableness provision should not be applied to interest which has its specific s. 20(1)(c) reasonableness limitation In refusing to apply s. 67 to interest that was found to be reasonable in amount for purposes of the reasonableness limitation expressed in s. 20(1)(c), McLachlin J. stated (at para. 51): "... it seems to me that Parliament intended s. 67 to apply primarily to those deductions claimed under the provisions of the Act that do not have their own internal limiting clauses.... ...