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(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. ...

Salomon and Company Limited, [1897] A.C. 22 that a corporation is regarded in law as a legal entity with the personality of its own and it is quite distinct from its shareholders" (p. 1592), Christie A.C.J. found (at p. 1596) "that a person who acquires a share in a corporation does not thereby acquire an interest in land that is an asset of the corporation", and accordingly refused to extend the principle in the Fraser case to find that loans made to a real estate company by its shareholder had the same character as if they had been incurred in connection with the business of that company. ...

" Lord Fraser found that the right to receive the additional consideration was an "asset" (broadly defined to mean all forms of property), and that although the additional amount was paid to satisfy or extinguish such right and not as part of the consideration for the sale of the shares, such sum was clearly "derived from" such asset (the deferred right) and therefore was deemed to be received in connection with a disposal. ...

CCRA then side-stepped this process by indicating it would not enforce the old requirements and instead applied for new requirements indicating that it was seeking the information about the third parties in connection only with its audit of the applicants. ...