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., cancellation) of the non-compete The taxpayer made a series of demands for parties to a non-compete agreement (that it had received in connection with its acquisition of a business) to comply with the agreement and, following negotiations and before the commencement by it of an action, it was agreed that it would be paid a lump sum in consideration for the cancellation of the non-compete agreement. ...

Canada, 2024 FCA 192, leave granted 22 May 2025 (41643)-- summary under French and English Version Summary Under Tax Topics- Statutory Interpretation- French and English Version “as a consequence of” interpreted in light of the shared meaning of the French and English versions In finding that the phrase “as a consequence of” in s. 161(7)(b)(iv) required a causal connection, Woods JA stated (at paras. 32-34): [B]oth the English and French versions of the proviso imply a causal element. ...

The case law requires a rational connection between the reasonably determined risk and the amount of the reserves. ...

Expense- Financing Expenditures refinancing fees not incurred in the course of earning income The taxpayers incurred various expenditures in connection with retiring existing bonds before maturity and issuing replacement bonds at a lower rate of interest and with less onerous conditions as to payment, including the payment of redemption premiums, disbursements on account of exchange, discounts paid to the underwriters on the issuance of the new bonds, and legal and printing expenses. ...

Regarding QSTA s. 199(c) (similar to ETA s. 169(1) – B(c)), St-Joseph argued based on QSTA s. 42.5 (similar to ETA s. 141.1(3)(a)) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

Turning to QSTA s. 199(c) (similar to ETA s. 169(1) – B(c)), she went on to reject an argument of St-Joseph based on QSTA s. 42.5 (similar to ETA s. 141.1(3)(a)) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

St-Joseph argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

St-Joseph argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

“Stewards,” being persons who had a commercial connection with such waste, were statutorily responsible for paying fees to the appellant to reflect their reasonable share of the associated costs. ...

“Stewards,” being persons who had a commercial connection with such waste, were statutorily responsible for paying fees to SO to reflect their reasonable share of the associated costs. ...