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. — “personal or living expenses includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ... See also s. 139(1)(ae) of the Income Tax Act which includes as “personal and living expenses and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

N.D.L. and International were totally unrelated companies; N.D.L. and its shareholders did not hold any shares in International either directly or indirectly or through related persons and International and its shareholders did not hold any shares in N.D.L. either directly or indirectly or through related persons; International's promoter and the designer of the particular Shuffler-Board model in question was a certain Cal Hayward, who had no connection with N.D.L. or N.D.L.’s shareholders. 7. ... Maredell Ltd. was formed, as the witnesses called by N.D.L., including the person who was the chairman of N.D.L.’s board of directors at the time of these events, explained, because N.D.L. through its board of directors felt that it was stuck, that it could not do anything else and that this was the only way both to save the accounts payable to N.D.L. in connection with the Shuffler-Boards that had been sold so far, and to take advantage of the opportunity offered by Watney's. 29. ...

In connection with these customers, the contracts indicate “BXL has installed the necessary on-site bulk explosives manufacturing facilities, raw materials storage and mobile equipment to service the individual bulk requirements of each of these customers”. ... Essentially it had been made “over-wide”, “over high”, and/or “over weight”, by various hoses, connections, tanks, fire fighting equipment, mixing bins, etc built onto the original chassis. ...

The applicants were cleared of any wrongdoing in that connection. The charges do not relate to the failure to remit. ... Paragraphs 231(l)(a) and (d) provide as follows: 231. (1) Any person thereunto authorized by the Minister, for any purpose related to the administration or enforcement of this Act, may, at all reasonable times, enter into any premises or place where any business is carried on or any property is kept or anything is done in connection with any business or any books or records are or should be kept, and (a) audit or examine the books and records and any account, voucher, letter, telegram or other document which relates or may relate to the information that is or should be in the books or records or the amount of tax payable under this Act. ...

In this Part, except as otherwise provided in section 5203 or 5204, “adjusted business income” of a corporation for a taxation year means the amount, if any, by which (a) the aggregate of all amounts each of which is the income of the corporation for the year from an active business carried on in Canada exceeds (b) the aggregate of all amounts each of which is the loss of the corporation for the year from an active business carried on in Canada; “cost of capital” of a corporation for a taxation year means an amont equal to the aggregate of (a) 10 per cent of the aggregate of ail amounts each of which is the gross cost to the corporation of a property referred to in paragraph 1100(1)(e),(f),(g) or (h), paragraph 1102(1)(d) or (g) or Schedule II that (i) was owned by the corporation at the end of the year, and (ii) was used by the corporation at any time during the year, and (b) the aggregate of all amounts each of which is the rental cost incurred by the corporation during the year for the use of any property a portion of the gross cost of which would be included by virtue of paragraph (a) if the property were owned by the corporation at the end of the year, but for the purposes of this definition, the gross cost of a property or rental cost for the use of any property does not include that portion of those costs that reflects the extent to which the property was used by the corporation during the year (c) in an active business carried on outside Canada, or (d) to earn Canadian investment income or foreign investment income as defined in subsection 129(4) of the Act; “cost of labour” or a corporation for a taxation year means an amount equal to the aggregate of (a) the salaries and wages paid or payable during the year to all employees of the corporation for services performed during the year, and (d) all other amounts each of which is an amount paid or payable during the year for the performance during the year, by any person other than an employee of the corporation, of functions relating to (i) the management or administration of the corporation, (ii) scientific research as defined in section 2900, or (iii) a service or function that would normally be performed by an employee of the corporation, but for the purposes of this definition, the salaries and wages referred to in paragraph (a) or other amounts referred to in paragraph (b) do not include that portion of those amounts that (c) was included in the gross cost to the corporation of a property (other than a property that was manufactured by the corporation and leased during the year by the corporation to another person) that was included in computing the cost of capital of the corporation for the year, or (d) was related to an active business carried on outside Canada by the corporation; “cost of manufacturing and processing capital” of a corporation for a taxation year means 100/85 of that portion of the cost of capital of the corporation for that year that reflects the extent to which each property included in the calculation thereof was used directly in qualified activities of the corporation during the year, but the amount so calculated shall not exceed the cost of capital of the corporation for the year; “cost of manufacturing and processing labour” of a corporation for a taxation year means 100/75 of that portion of the cost of labour of the corporation for that year that reflects the extent to which (a) the salaries and wages included in the calculation thereof were paid or payable to persons for the portion of their time that they were directly engaged in qualified activities of the corporation during the year, and (b) the other amounts included in the calculation thereof were paid or payable to persons for the performance of functions that would be directly related to qualified activities of the corporation durng the year if those persons were employees of the corporation, but the amount so calculated shall not exceed the cost of labour of the corporation for the year; “gross cost” of a property means the capital cost of the property computed without reference to subsection 13(7.1) or (10) or section 21 or 80 of the Act; “qualified activities” means (a) any of the following activities, when they are performed in Canada in connection with manufacturing or processing (not including the activities listed in subparagraphs 125. l(3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease: (i) engineering design of products and production facilities, (ii) receiving and storing of raw materials, (iii) producing, assembling and handling of goods in process, (iv) inspecting and packaging of finished goods, (v) line supervision, (vi) production support activities including security, cleaning, heating and factory maintenance, (vii) quality and production control, (viii) repair of production facilities, and (ix) pollution control, (b) all other activities that are performed in Canada directly in connection with manufacturing or processing (not including the activities listed in subparagraphs 125. l(3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease, and (c) scientific research as defined in section 2900, but does not include any of (d) storing, shipping, selling and leasing of finished goods, (e) purchasing of raw materials, (f) administration, including clerical and personnel activities, (g) purchase and resale operations, (h) data processing, and (i) providing facilities for employees, including cafeterias, clinics and recreational facilities; “rental cost” of a property means the rents incurred for the use of that property; “salaries and wages” means salaries, wages and commissions, but does not include any other type of remuneration, any superannuation or pension benefits, any retiring allowances or any amount referred to in section 6 or 7 of the Act. ...

(c) The term “Senior Indebtedness” means the principal of and interest on: (i) indebtedness, other than the Subordinated Notes, whether outstanding on the date of this agreement or hereafter created, incurred, assumed or guaranteed, which is for money borrowed by the Company or for money borrowed by others for the payment of which the Company is responsible or liable; (ii) indebtedness created, incurred, assumed or guaranteed by the Company in connection with the acquisition by it or a subsidiary of any other business, properties or other assets; and (iii) renewals, extensions and refundings of any such indebtedness; unless in each case it is provided by the terms of the instrument creating or evidencing such indebtedness that such indebtedness is not superior in right of payment to the Subordinated Notes. ... The term “Senior Indebtedness” means the principal of and interest on: (a) indebtedness, other than the Notes, whether outstanding on the date of this Subordinated Promissory Note or hereafter created, incurred, assumed or guaranteed, which is for money borrowed by the Company or for money borrowed by others for the payment of which the Company is responsible or liable; (b) indebtedness created, incurred, assumed or guaranteed by the Company in connection with the acquisition by it or a subsidiary of any other business, properties or other assets; and (c) renewals, extensions and refundings of any such indebtedness; unless in each case it is provided by the terms of the instrument creating or evidencing such indebtedness that such indebtedness is not superior in right of payment to the Subordinated Promissory Notes. 4. ...

The assumptions of facts alleged by the respondent in the present case are as follows: (a) at all material times, the Appellant was not carrying on a farming business; (b) the expenses incurred by the Appellant in relation to his farming activities, constituted expenses of properties maintained by the Appellant for the use or benefit of the Appellant or any person connected with the Appellant by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit; (c) the expenses incurred by the Appellant in relation to his farming activities were personal or living expenses of the Appellant. 3. ... —"personal or living expenses” includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relation- ship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

In connection with section 12(1)(c), as I understand it, the Minister is saying that interest accrued up until the transaction date is not interest to the purchaser whereas interest accrued between the transaction date and the maturity date or the date the security is sold is interest. ... In this connection, I would make general reference to Smith, Stone and Knight Ltd v Birmingham Corp, [1939] 4 All ER 116. ...

The connection between the legal services thus acquired and the taxpayer’s business neither requires nor permits reference to the taxpayer’s state of mind. The nature of that connection is to be found in the objective facts found by his Honour or not in dispute between the parties. ...

In that connection the word “exclusively” used both in section 91 and in section 92 indicates a settled line of demarcation and it does not belong to either Parliament, or the Legislatures, to confer powers upon the other. ... I do not see any real connection between the Lord Nelson Hotel case, which was a matter of delegation of powers, the Winterhaven case, which involved spending, but not delegation, and the present case, which involves the question of direct taxation by Federal Income Tax and GST within a province. ...