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A proposed structure on a site which it planned to rent to tenants was therefore intended to be used in connection with its business, i.e., renting out a property is a "use" of property. ...

., 64 DTC 5184, [1964] CTC 294 (Ex Ct)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) no "conferral" if corporation is advancing its business In 1953 two subsidiaries of the taxpayer waived the interest that was coming due on two loans they had made to the taxpayer a year previously, and a year later all the further interest was waived in connection with the repayment by the taxpayer of a portion of the principal in full satisfaction of the loans. ...

In finding that there have been no misrepresentation by the taxpayer in connection with not including these amounts in his income, Mr. ...

In finding that B.V. was carrying on an active business, MacKay J. noted that the investing activities of B.V. were within the scope of the objectives set out in its articles of incorporation, supervising managing directors of B.V. met on a quarterly basis, B.V. through its supervisory director had investigated making other acquisitions in addition to those that it actually made, it used staff resources provided by affiliated companies in Amsterdam in connection with receiving and accounting for payments made on the note, and indicated that it was not appropriate for the Minister's reassessment not to relate to the whole of the income of B.V. so that the concession of the Minister that interest on the loan was from an active business assisted the taxpayer's position. ...

The taxpayer claimed input tax credits on expenses relating to the operation of a private jet, which were incurred primarily in connection with Mr. ...

C Miller J found that an obiter dictum in O'Dwyer, dealing with a similar issue in connection with a s. 237.1(7.4) penalty, was apt (para. 27, citing O'Dwyer at para. 31): [S]imply reiterating the multiple combinations of possibilities that could result in the imposition of the penalty does not tell a taxpayer what specific act (that would result in the imposition of the penalty) he or she is alleged to have committed. ...

Although the Canadian agents issued "conditional receipts" in Canada providing temporary insurance, the policies which the taxpayer ultimately issued in the United States following the completion of the underwriting process stated that the final contract and the application (in connection with which the conditional receipts were issued) were one entire contract, and it was clear that those contracts were concluded in the United States rather than in Canada. ...

The Queen, 2001 DTC 243 (TCC)-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer, who owned a portion of the shares of the holding company ("GH") which, in turn, owned an operating company ("GBC") utilized the enhanced capital gains exemption in connection with the sale of a cement plant operated by GBC through the following transactions: the taxpayer and the other shareholders of GH transferred a portion of their shares of GH to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to GH; GH redeemed the common shares held in its capital by Newco by transferring to Newco the assets it had received from GBC; and the shareholders of Newco's sold their interests in Newco to the purchaser (who also purchased the remaining cement-plant assets directly from GBC). ...

The factors were examined and a rational conclusion was reached on each: There was no causal connection between [director] Mr Dakha's injury and the failure to meet tax obligations as there was another director capable of meeting the fiscal obligations. ...

The Queen, 2005 TCC 92-- summary under Paragraph 141.1(3)(b) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(b) action brought by trustee for bankrupt financial institution deemed to be not in course of commercial activity The trustee in bankruptcy for a company ("Castor") which had essentially only engaged in investing in high-yield loans brought an action in its capacity of trustee for the Castor estate against the former auditors ("C&L") for $40 million in damages for breach of contract, and also began a "litigation support business" of providing assistance to most of the creditors (the "Participating Creditors"), including hiring professionals and experts, in connection with their action sounding in negligence against C&L for $800 million in damages. ...