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However, in connection with the sale in 2005, they discovered that (due to some communication difficulties relating to a change in the taxpayer's counsel) the corporate minute books recorded only one share as having been issued to each of them. ...

., 86 DTC 6097, [1986] 1 CTC 284 (FCA)-- summary under Regulation 805 Summary Under Tax Topics- Income Tax Regulations- Regulation 805 dividends, being themselves income from property, were not exempted notwithstanding their commercial connection to the recipinent's business Dividends that the taxpayer paid to a US shareholder (“Penn Central”) were, as an historical matter, in lieu of amounts that Penn Central otherwise might have derived from the leasing of a railway line used in its business. ...

In finding that the appellant was entitled to input tax credits for GST on the fees incurred by it in connection with this listing, C Miller J found that ss. 186(1) and 186(2) both applied, so that the appellant was deemed to incur the fees for use in its commercial activities. ...

Before going on to find that s, 186(2) also applied so as to provide input tax credits for GST on the fees incurred by the appellant in connection with this listing, C Miller J found that s. 186(1) applied to deem the appellant to incur the fees for use in its commercial activities, stating (at paras. 16-17): The facts are quite clear – the listing services were acquired so that Stantec could complete its deal to own all the shares of the company resulting from the merger of Keith Companies and Stantec California. ...

In December 2003, in connection with a number of fish harvesters, the CRA offered to treat half of their [licence retirement program] payments as non-taxable, and the other half as capital gains. ...

Mainville J.A. stated (at paras. 5-6): Whereas business goodwill was formerly considered to pertain to good name, reputation and connection principally with respect to customer relations, the concept has now taken on a broader meaning influenced by economic, accounting and valuation theories. ...

Rothstein J. stated (at para. 56): The fact that the language of s. 248(10) allows either prospective or retrospective connection of a related transaction to a common law series and that such an interpretation accords with Parliamentary purpose, impels me to conclude that this interpretation should be preferred to the interpretation advanced by Copthorne [that "in contemplation of" is prospective only]. ...

In connection with finding that the equipment qualified in the taxpayer's hands as depreciable property, McLachlin J. stated (at para. 7): The fact that the assets produced revenue, as the reasons of L’Heureux-Dubé J. demonstrate, establishes that they continued to be used for the purpose of producing income, avoiding the effect of s. 13(7)(a) and the exclusion under Regulation 1102(1)(c). ...

The Queen, 2015 TCC 197-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply cellphone connection to a US telephone network, and transmission of call to Canada, were part of a seamless single supply to Canadian customer The appellant ("Telus") operated a wireless carrier business which entailed providing roaming airtime ("RAT") services to customers, with Canadian billing addresses, who while in the U.S. made long-distance call to Canada. ...

The Queen, 2015 TCC 197-- summary under Paragraph 142.1(2)(b) Summary Under Tax Topics- Excise Tax Act- Section 142.1- Paragraph 142.1(2)(b) cellphone connection to a US telephone network, and transmission of call to Canada, were part of a seamless single supply to Canadian customer The appellant ("Telus") operated a wireless carrier business which entailed providing roaming airtime ("RAT") services to customers, with Canadian billing addresses, who while in the U.S. made long-distance call to Canada. ...