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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. ...

Graham J accepted the submission of the applicants (the designated partners of the partnerships) in connection with a Rule 58 determination that the Minister could not issue a valid Notice of Determination if the Minister had concluded that the partnership in question did not exist – so that the Notices of Determination were invalid. ...

Such surrenders occurred (and were previously contemplated in agreements with purchaser corporations to occur) in connection with the acquisition of all their shares by unrelated corporate purchasers. ...

Such surrenders occurred (and were previously contemplated in agreements with purchaser corporations to occur) in connection with the acquisition of all their shares by unrelated corporate purchasers. ...

The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115-- summary under Paragraph 250.1(a) Summary Under Tax Topics- Income Tax Act- Section 250.1- Paragraph 250.1(a) s. 250.1 applies only to persons who would not be taxpayers under Oceanspan An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his purported unused tuition tax credits as a deduction from Canadian tax. ...

The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115-- summary under Taxpayer Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxpayer an individual not within s. 2(1) or (3) was not a taxpayer who could generate a tuition tax credit An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his purported unused tuition tax credits as a deduction from Canadian tax. ...

Furthermore, she found that 9267 had not taken reasonable measures to pursue collection of its debt, including claiming under its security interest, and having its debt included in the debtor claims made against 9210 in connection with the receivership and bankruptcy proceedings. ...

There is a direct and immediate connection between the production of potash and the subsequent sale or disposition of that potash. ...

The King, 2023 TCC 93-- summary under Subsection 141.01(4) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(4) Amex did not make “free” supplies of rewards to credit card holders but instead were made for consideration and for the purpose of facilitating its exempt credit card business The Minister denied the input tax credit (“ITC”) claims of Amex Bank of Canada’s (“Amex”) for its 2002 to 2012 taxations years for GST/HST paid on expenses arising in connection with the administration and operation of Amex’s Membership Rewards Program (“MRP”), including expenses incurred for the purpose of providing its cardholders who were members of the MRP (“Members”) with rewards on the redemption of points earned by them mostly through making purchases on their cards. ...