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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. ...

Redrow Group plc, [1999] UKHL 4, [1999] 2 All ER 13, [1999] 1 WLR 408-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) As an incentive to purchasers of its new homes, a residential home developer entered into agreements with prospective purchasers and real estate agents selected by it under which it agreed to pay the agent's fee plus VAT in connection with a sale of the existing purchaser's home, provided that the purchaser completed a purchase of a new home. ...

Before completion of the IPO, the Fund, Trust, appellant and its general partner entered into a "Financing Agreement" in which they agreed that all financing expense in connection with the IPO, other than the underwriters' fee, were to be incurred on behalf of the appellant; and at the same time the appellant entered into an "Administration Agreement" with the Fund in which it agreed to administer the Fund and "as agent of the Fund" to pay for all outlays and expenses incurred by it in such administration. ...

Hogan J. concluded that the appellant was a builder on applying the six tests in Happy Valley Farms of what constitutes an adventure in the nature of trade: the nature of the property sold, the length of ownership, the frequency or number of other similar transactions by the taxpayer, the work performed on or in connection with the property, the circumstances giving rise to the sale and, finally, motive, stating (at para. 10): The evidence before me reveals a clear pattern adopted by the Appellant of building a home, living in it for a period of time and reselling it at profit. ...

Polsinelli is agent of Sani‑Clean; it is a question of wanting to resign as director and sending the letter of resignation to the person who has any remaining responsible connection with Sani‑Clean and, in the circumstances, that was Mr. ...

Canada, 2013 FCA 176-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) term deposits paid to secure potential anti-dumping duty The taxpayer ("Perron") made cash term deposits in connection with its potential liability for countervailing and anti-dumping duties imposed by American trade authorities on Canadian softwood lumber exports, to the Royal Bank and pledged them in favour of the bank as security for irrevocable letters of credit issued by the bank to Perron's insurance company, which in turn issued a bond guaranteeing Perron's potential liability to the U.S. government. ...