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., ticket sales and the sale of food, beverages and souvenirs) in connection with the production of a figure skating show in Canada by Marco. ...

In finding that the liquidating distribution also was a non-arm's length transaction (notwithstanding that the B.C. company statute "did not empower the shareholders, as a body, to dictate action to be taken by the liquidator" (p. 1072), Thurlow J. stated (p. 1072): "The three shareholders, in determining to wind-up the company, had a common purpose to get rid of certain difficulties which were being encountered in connection with the company by winding it up and, at the same time, having a new company take over its undertaking. ...

In computing the loss, the taxpayer deducted from the proceeds of sale of a property amounts paid into court in connection with outstanding liens placed on the property at the time a building was constructed on it, even though the amount remained in court for some time after 1975. ...

(f) not engaged where fee owner transferred beneficial ownership then registered title A wholly-owned subsidiary ("Realty") of the Toronto-Dominion Bank (the "Bank") was dissolved and in connection with that dissolution, Realty directed that land which it previously had owned in fee simple be conveyed to the Bank which, in turn, directed that legal title be held by Realty as bare trustee. ...

Before concluding that Anwin was not a partnership, Evans J. found that Anwin was not carrying on a business given that construction of the Anaquan research facility was never completed and Anwin engaged only in several financial transactions around the time of its closing in connection with its purported establishment, and that any business would not have been carried on with a view to profit. ...

Tax Treaty, which provided that a resident of a contracting state who carried on activities in the other state in connection with exploration or exploitation of the seabed and sub-soil and the natural resources situated in the other contracting state was deemed to be carrying on business in the other contracting state through a permanent establishment situated therein. ...

It was not clear which authority governed- the test in ExxonMobil that the allowance not be for the "exclusive personal use" of the employees, or the test in Midland Hutterian Brethren that there be a "functional connection between the needs of the business and the goods" (or services, in this case). ...

It was not clear which authority governed- the test in ExxonMobil that the allowance not be for the "exclusive personal use" of the employees, or the test in Midland Hutterian Brethren that there be a "functional connection between the needs of the business and the goods" (or services, in this case). ...

This question, in turn, rested upon determining whether the nature of the relationship between Telecom and the telephone companies its served (notably, Bell Canada, viewed as having a communications undertaking within federal jurisdiction), including the importance of the installation work done for Bell Canada and the physical and operational connections between the installation department and the core federal undertaking of Bell Canada, were such as to make the installation department part of that undertaking. ...

Commissioner of Internal Revenue (1990), 93 T.C. 67-- 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 The petitioner, whose shares were traded on the NYSE, incurred legal fees of $490,000 and a fee of $2.2 million from Morgan Stanley (primarily for a fairness opinion) in connection with the friendly take-over bid of the petitioner by the Unilever Group pursuant to which shareholders of the petitioner had a choice between receiving cash or exchanging their shares on a rollover basis for shares of a Unilever company. ...