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The Queen, 2005 TCC 92-- summary under Paragraph 265(1)(f) Summary Under Tax Topics- Excise Tax Act- Section 265- Subsection 265(1)- Paragraph 265(1)(f) trustee's own suit and litigation support activity were related The trustee in bankruptcy for a company ("Castor") which had essentially only engaged in investing in high-yield loans brought an action in its capacity of trustee for the Castor estate against the former auditors ("C&L") for $40 million in damages for breach of contract, and also began a "litigation support business" of providing assistance to most of the creditors (the "Participating Creditors"), including hiring professionals and experts, in connection with their action sounding in negligence against C&L for $800 million in damages. ...

The Queen, 2005 TCC 92-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business litigation support services provided by trustee for bankrupt financial institution were an "undertaking" The trustee in bankruptcy for a company ("Castor") which had essentially only engaged in investing in high-yield loans brought an action in its capacity of trustee for the Castor estate against the former auditors ("C&L") for $40 million in damages for breach of contract, and also began a "litigation support business" of providing assistance to most of the creditors (the "Participating Creditors"), including hiring professionals and experts, in connection with their action sounding in negligence against C&L for $800 million in damages. ...

The Queen, 83 DTC 5288, [1983] CTC 289 (FCA)-- summary under Similar Statutes/ in pari materia Summary Under Tax Topics- Statutory Interpretation- Similar Statutes/ in pari materia wide assortment of statutes not in pari materia In connection with finding that a statement in the Excise Tax Act that taxes payable thereunder were recoverable "at any time" meant that no statute of limitations barred any claim for taxes in the current proceedings, Clement DJ stated (at p. 5293, DTC): Both counsel referred to a wide assortment of statutes that employ the phrase "at any time" in a variety of contexts. ...

Canada, 98 DTC 6630, [1999] 1 CTC 1 (FCA)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 notional separate enterprise would not have rented the equipment The taxpayer, which was resident in the United States, entered into a contract to provide two "snubbing" units to Mobil Oil Canada Ltd. for use in connection with an underground blowout in an exploratory gas well off the coast of Nova Scotia, at a rate of U.S. $15,000 per day. ...

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. ...

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. ...