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It was reasoned that the mere holding of inventory does not constitute a use of the property for an income-producing purpose in the context of considering a conversion of depreciable property to inventory (or vice versa) – whereas inventory should be considered to be income-producing property in the context of a conversion of personal-use property to inventory, or vice versa. ...

Sharlow JA stated (at para. 13): In my view, there has been in this case a transmission of the liability of the Taxpayer Trust to another person by "other means" – which I take to include the termination of the existence of the taxpayer. ...

Sharlow JA stated (at para. 13): In my view, there has been in this case a transmission of the liability of the Taxpayer Trust to another person by "other means" – which I take to include the termination of the existence of the taxpayer. ...

. … In my view, the interpretation of the contracts that is more consistent with the language of the contracts and the undisputed facts is that [such] payments were consideration paid by Amex to Costco, either for Costco entering into the Co-Branding Agreement, or specifically for the exclusivity provision. ...

. … As a matter of law it does not follow that, because the solicitor-client relationship is generally one of agency, all financial obligations incurred by a lawyer while providing legal services are incurred as agent of its clients. ...

. … While holding an ATP may exempt one from the application of the criminal law, it is not an “exemption” as contemplated by fiscal legislation…. ...

A submission of the appellant that he should not be liable for the unremitted GST of the company because the Minister took too long to assess (over 10 years), was rejected as being inconsistent with Addison & Leyen. ...

. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. ...

Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) inconsistent assessments of related taxpayers A Barbados corporation reported substantial profits from the sale of a herbicide to Canadian farmers, and deducted amounts paid to a non-arm’s length Canadian corporation (AgraCity – which was the taxpayer in the case) as service fees. ...

Leonati, [1996] 3 S.C.R. 458 … at paragraph 51). In the present case, all of the evidence necessary to consider the applicability of subsection 253(b) of the Act was adduced at trial and I am satisfied that the respondent will not be prejudiced by allowing the appellant to raise this argument; it was the respondent who raised at trial the issue of whether the appellant was carrying on business in Canada when the loss on the sale of shares was incurred ...