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The Minister's choice of words seems revealing in this connection: He refers to "new multiple-unit residential buildings" to describe buildings the construction of which he wants to encourage, but refers to the "owner of an eligible rental unit’ [emphasis added] to describe a taxpayer he is seeking to benefit. ...

The appellant had been employed only a short time as a commission salesman of M Greene & Associates Limited, security dealers (hereinafter referred to as “Greene & Associates’’) when he met one Dr W N Ingham, a consulting geologist, who was at the time of their meeting doing work for Greene & Associates in connection with a mining property in which they were interested. ...

In this connection, you have requested that consideration be given to application of the provisions of Section 29(2b)(a) and (b) of the Excise Tax Act with respect to the floating concrete docks of your manufacture. ...

All the cardholders would have known was that the ATMs offered a connection to a network that would allow them to withdraw money from their own accounts. ...

It is a matter for surprise that in the appeal at bar the respondent is using the special nature of Quebec civil law as a reason for denying the appellant a deduction which is granted to taxpayers and businessmen operating under the common law system. [25]      Accordingly, for the year 1982 at issue, the Information Bulletin identified four types of lease acquisitions which, made in connection with a leasing transaction, were to be treated for tax purposes like sales or deemed to constitute a sale: (a)      the lessee automatically acquires title to the property after payment of a specified amount in the form of rentals; (b)      the lessee is required to buy the property from the lessor during or at the expiration of the lease, or is required to guarantee that the lessor will receive the full option price from the lessee or a third party; (c)      the lessee has the right during or at the expiration of the lease to acquire the property at a price which at the inception of the lease is substantially less than the probable fair market value of the property at the time or times of permitted acquisition by the lessee; and (d)      the lessee has the right during or at the expiration of the lease to acquire the property at a price or under terms and conditions which at the inception of the lease is/are such that no reasonable person would fail to exercise the said option. [26]      The respondent admitted that the transaction to which the appellant was a party could be described as a sale both pursuant to tests (c) and (d) set out in the Interpretation Bulletin. [27]      In my view, it would be inappropriate for this Court to ignore or repudiate the content of the said Bulletin 17 years later, as the respondent is asking us to do in the case at bar, since the Bulletin clearly and correctly reflects the state of the legislation and case law applicable in tax matters at the time to property acquired by a taxpayer through a leasing transaction. ... Since the cost of exercising the option at the time provided for its exercise was slightly below the five unpaid monthly payments, 20 it may be assumed that the appellant would not have hesitated to exercise it as intended by paragraph 3(3) of the Interpretation Bulletin, especially considering the "probable" value of the property within the meaning of paragraph 3(c). [20]          In this connection the evidence showed that with the passage of time the International trucks had in fact a market value varying between $38,000 and $49,000 per unit after five years of use. 21 As to the "probable" value of the equipment insofar as it could be estimated when the contracts were signed Victor Fortin, the appellant"s president, testified as follows: [TRANSLATION] Listen, at the time we estimated, I cannot express any thought, but in my mind, Your Ladyship, a truck is worth, so long as it is well maintained, five years is not its life, that is not right. ... In this connection it cited the dictum of Dickson C.J. in Bronfman Trust v. ...

That subsection, which is in the same terms as it was then, except for a reference to a new subsection 44(2.1), reads as follows: (2) Where goods have been purchased by Her Majesty in right of any province of Canada for any purpose other than (a) resale; (b) use by any board, commission, railway, public utility, university, manufactory, company or agency owned, controlled or operated by the government of the province or under the authority of the legislature or the lieutenant governor in council, or (c) use by Her Majesty or by Her agents or servants in connection with the manufacture or production of goods or use for other commercial or mercantile purposes, a refund of taxes paid under Part Ill, IV or V may be granted to Her Majesty or to the importer, transferee, manufacturer, producer, wholesaler, jobber or other dealer as the case may require. ...

That definition reads as follows: “RRSP strip”, in respect of a RRIF or RRSP, means an amount used or obtained by the controlling individual of the RRIF or RRSP, or a person who does not deal at arm’s length with the controlling individual, as part of a transaction or event or a series of transactions or events one of the main purposes of which is to enable the controlling individual, or a person who does not deal at arm’s length with the controlling individual, to use or obtain the benefit of property held in connection with the RRIF or RRSP, but does not include an amount that is « somme découlant d’un dépouillement de REER » Relativement à un FERR ou à un REER, toute somme utilisée ou obtenue par le particulier contrôlant du FERR ou du REER, ou par une personne avec laquelle celui-ci a un lien de dépendance, dans le cadre d’une opération ou d’un événement, ou d’une série d’opérations ou d’événements, dont l’un des objets principaux consiste à permettre au particulier contrôlant ou à une personne avec laquelle il a un lien de dépendance d’utiliser un bien détenu dans le cadre du FERR ou du REER ou d’en tirer profit. ...

(d) Assisting any persons by paying their expenses in connection with their standing for election for Parliament or other public Assemblies. ...

(p) an outlay or expense to the extent that it was made or incurred by a corporation in a taxation year for the purpose of gaining or producing income from a personal services business, other than p) une dépense, dans la mesure où elle est engagée ou effectuée par une société au cours d'une année d'imposition en vue de tirer un revenu d'une entreprise de prestation de services personnels, à l'exception: (i)            the salary, wages or other remuneration paid in the year to an incorporated employee of the corporation, (i)            du salaire, du traitement ou d'une autre rémunération versé au cours de l'année à un actionnaire constitué en société de la société, (ii)           the cost to the corporation of any benefit or allowance provided to an incorporated employee in the year, (ii)           du coût, pour la société, de tout autre avantage ou allocation accordé à un actionnaire constitué en société au cours de l'année, (iii)          any amount expended by the corporation in connection with the selling of property or the negotiating of contracts by the corporation if the amount would have been deductible in computing the income of an incorporated employee for a taxation year from an office or employment if the amount had been expended by the incorporated employee under a contract of employment that required the employee to pay the amount, and (iii)          d'un montant dépensé par la société et lié à la vente de biens ou à la négociation de contrats par la société, lorsque le montant aurait été déductible dans le calcul du revenu d'un actionnaire constitué en société pour une année d'imposition tiré d'une charge ou d'un emploi s'il l'avait dépensé en vertu d'un contrat d'emploi qui l'obligeait à verser le montant, (iv)          any amount paid by the corporation in the year as or on account of legal expenses incurred by it in collecting amounts owing to it on account of services rendered (iv)          d'un montant versé par la société au cours de l'année au titre des frais judiciaires ou extrajudiciaires engagés par elle en recouvrement des sommes qui lui étaient dues pour services rendus, that would, if the income of the corporation were from a business other than a personal services business, be deductible in computing its income; qui serait, si le revenu de la société était tiré d'une entreprise autre qu'une entreprise de prestation de services personnels, déductible dans le calcul de son revenu; [47]            In the most common situation involving paragraph 18(1)(p) of the Income Tax Act, no deduction is permitted for such ordinary business expenses as rent, telephone costs, administration and office costs, and remuneration to any employee other than the "incorporated employee". ...

  [51]      This finding is consistent with the summary of tax effects sent to the shareholders in connection with the PSO (see para. 24, above). ...