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Although there were large interest-free loans owing by the corporation to the shareholder (the taxpayer), Teskey J held that there was no connection between such loans and the original cost of the house, so that the benefit arising to the taxpayer under s. 15(1) should not be reduced having regard to the interest-free nature of the loans and the making of such a reduction in Youngman. ...

Guindon, 2013 DTC 5133 [at at 6117], 2013 FCA 153, aff'd supra-- summary under Section 11 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 11 The taxpayer provided grossly negligent opinions on a charitable donation scheme (which unbeknownst to her was a scam) and signed charitable donation receipts in connection therewith. ...

Guindon, 2013 DTC 5133 [at at 6117], 2013 FCA 153, aff'd supra-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) The taxpayer provided grossly negligent opinions on a charitable donation scheme (which unbeknownst to her was a scam) and signed charitable donation receipts in connection therewith. ...

., 2002 DTC 7517, 2002 FCA 408-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital cost of assets purchased with treasury shares was the agreed purchase price being the shares’ stated capital In connection with a privatization transaction and at a time that it was still owned by the federal Crown, the taxpayer purchased assets for a stipulated purchase price that was less than the price at which an arm's length purchaser had committed (pursuant to the same agreement under which the asset sale occurred) to purchase the common shares of the taxpayer. ...

., 2002 DTC 7517, 2002 FCA 408-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base cost of assets acquired was the stated capital of the shares issued therefor, being the agreed transaction value In connection with a privatization transaction and at a time that it was still owned by the federal Crown, the taxpayer purchased assets for a stipulated purchase price that was less than the price at which an arm's length purchaser had committed (pursuant to the same agreement under which the asset sale occurred) to purchase the common shares of the taxpayer. ...

The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose finding an acquirer to maximize shareholder value The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

" In light of the fact that the taxpayers were members of two Amway networks which had their bases in North Carolina and Maine, the expenses they incurred in attending the meetings in the U.S. were found to have been incurred in connection with their business and in a location reasonably consistent with the territorial scope of the two organizations. ...

The Queen, 95 DTC 164 (TCC), briefly aff'd 97 DTC 5012 (FCA)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Legal and accounting fees paid by the taxpayer in connection with the preparation of management circulars, which were sent to shareholders in response to three take-over bids, were fully deductible. ...