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Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose direct causal connection to income need not be demonstrated In response to a submission that mining machinery and equipment had not been purchased "for the purpose of earning income" because the profits initially generated by the mine would be eligible for a federal and provincial tax holiday, Wilson J. stated: If [as established in case law cited by her] there is no need to demonstrate a causal connection between a particular expenditure and a particular income, and no need for the income to be generated in the same year in which the expenditure was made, then it would not seem to matter whether Mattabi suffered tax losses in 1971 or that it would have been exempt from tax had it made a profit. ...

., 2021 SCC 49, [2021] 3 S.C.R. 590-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a company resident under Luxembourg domestic law (its legal seat was there), and that was “liable to be liable to tax,” was resident there for Treaty purposes even though a conduit In considering whether there had been a treaty-shopping abuse of the Canada-Luxembourg Treaty by virtue of the taxpayer, which had its legal seat in Luxembourg, but was a “conduit entity” without a substantial economic connection to Luxembourg, accessing a Treaty exemption for a capital gain on its disposition of a Canadian resource company, Côté J stated (at paras. 53-54-56, 58): [T[he use of the word “means” in this provision indicates that the definition should be “construed as comprehending that which is specifically described or defined” and thus as setting out all requirements that must be met to be considered a resident under the Treaty …. ... [A]rt. 4(1) … expressly states that residence is to be defined by the laws of the contracting state of which the person claims to be a resident. … [T]his preference for leaving the meaning of residence to domestic law is totally consistent with the scheme of the Treaty. … It is worth noting that the words “sufficient substantive economic connections” are conspicuous by their absence in the text of both arts. 1 and 4. ...

It accordingly did not occupy its premises in connection with a "business" (s.7(1), Assessment Act (Ont)). ...

The taxpayer also realized a taxable gain when rights which it received in connection with the same shares were exercised by it and the shares acquired in exercise immediately sold by it. ...

Minister of National Revenue, 66 DTC 5116, [1966] CTC 150, [1966] S.C.R. 384-- summary under Scheme Summary Under Tax Topics- Statutory Interpretation- Scheme In connection with finding that land upon which the timber had been removed should be regarded as part of a timber limit, in order to avoid the deduction by the taxpayer of depreciation in excess of the net cost to it of the land, Cartwright J. stated (p. 5120): "The answer to the question what tax is payable in any given circumstances depends, of course, upon the words of the legislation imposing it. ...

Canada, 95 DTC 5551, [1995] 3 S.C.R. 103-- summary under Inventory Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Inventory property held in an adventure was inventory Major J. found that a real estate property held by the taxpayer and others in connection with an adventure or concern in the nature of trade qualified as "inventory" even though it did not represent stock-in-trade of a trading business. ...

., 2021 SCC 51, [2021] 3 S.C.R. 687-- summary under Certainty Summary Under Tax Topics- Statutory Interpretation- Certainty full effect should be given to Parliament’s precise and unequivocal words to produce certainty In connection with finding that the “business conducted” by a Barbados subsidiary of the taxpayer did not include its activities of raising capital from its shareholder (the taxpayer), Côté J stated (at para. 61, after having made the same point at greater length at para. 41): [I]f taxpayers are to act with any degree of certainty, then full effect should be given to Parliament’s precise and unequivocal words. ...

This did “ not depart from accepted usage such that the bargain struck in the Treaty could be upheld only if Luxembourg residents claiming benefits have ‘sufficient substantive economic connections’ to their country of residence” (para. 61). This conclusion was further reinforced by Art. 28(3) which (in contrast to the “look-through” approach in other contemporaneous treaties negotiated by Canada), denied Treaty benefits for “holding companies with minimal economic connections to Luxembourg” only in the case of some such holding companies (para. 65, see also para. 66). ...

Rowe and Martin, JJ, jointly speaking for the minority of three, accepted (at para. 151) that, under the Treaty, the “ allocation of taxing powers follows the theory of ‘economic allegiance’," under which “taxes should be paid on income where it has the strongest ‘economic interests’ or ties, either in the state of residence or the source state,” – whereas here there was an abuse of that Treaty object since the “evidence demonstrate[d] that Alta Luxembourg had no genuine economic connections with Luxembourg as it was a mere conduit interposed in Luxembourg for residents of third-party states to avail themselves of a tax exemption under the Treaty” (para. 177). ... Indeed, Canada’s acceptance of the use of conduit corporations was implicit in Art. 28(3), which provided a very narrow exception to Treaty residence status for only certain, rather than all, types of “holding companies with minimal economic connections to Luxembourg” (para. 65, see also para. 66). ...

I say this because that individual first referred to is next referred to in connection with his family. ...