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In this connection, the respondent also indicated he was unable to further consider the application until clause 2 was formally amended, except for subclauses (b) and (k) which were viewed as “merely powers or enabling clauses" which could stand unamended. ...

The expenditures were made in respect of a business (that of United Trust), 2. aS a result of a transaction (the issuance of shares and the payment of a commission in connection therewith), 3. which occurred after 1971, 4. on account of capital (those moneys raised from the issuance of shares). 5. which, in turn, was for the purpose of producing income (as described in the prospectus earlier quoted herein) and 6. were outlays or expenses not otherwise deductible by virtue of any provision of the Act, other than subsection 18(1)(b), in computing income from the business. ...

Both of the latter terms include the phrase “ qualified activities". “ Qualified activities” is defined to mean, inter alia... all other activities that are performed in Canada directly in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease... ...

The Home Carrier shall also be responsible for billing its customers for, and remitting to, the Federal Government all federal excise tax that may be due in connection with the service being billed by it to its customers. ...

For example, certain administrative activities-- such as the collection of amounts by a bank in connection with a loan which was issued by the bank and the mailing out of monthly statements by that bank-- cannot really be separated from the service of providing the loan itself. ...

.: The issue in this appeal is whether the Appellant, in computing its income under the Income Tax Act (the Act) for the 1990 taxation year, was entitled to deduct an amount of $26,089,145 as a writedown of deposits on land for development, including preliminary development costs expended in connection therewith. ...

In consideration of the return of the said funds and promissory note to me, I hereby release the four general partners from any liability to me in connection with the partnership. ...

The three shareholders, in determining to wind up the company, had a common purpose to get rid of certain difficulties which were being encountered in connection with the company by winding it up and, at the same time, having a new company take over its undertaking. ...

  (1)        Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:   …   (p) Bad debts – the total of               (i)         all debts owing to the taxpayer that are established by the taxpayer to have become bad debts in the year and that have been included in computing the taxpayer’s income for the year or a preceding taxation year; and   Minister’s Position   [10]          In reassessing the Appellant, the Minister disallowed a bad debt deduction under subparagraph 20(1)(p)(i) on the basis that the loss in connection with the promissory note was capital in nature [3]. ...

I find it impossible to adopt the view that a person who, by having the requisite voting power in a company subject to his will and ordering, can make the ultimate decision as to where and how the business of the company shall be carried on, and who thus has, in fact, control of the company’s affairs, is a person of whom it can be said that he has not in this connection got a controlling interest in the company.” ...