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However, in a recent judgment this Court undertook to reject that approach, and I take the liberty of citing what I then wrote in this connection in the reasons submitted for the Court (Francine Légaré v. ...

The additional factor seems to be that where a high degree of commerciality is to be found in connection with the premises (such as there being stores and offices), the rentals received will be treated as income from a business without regard to the level of services offered and without regard to the fact that the landlord is an individual rather than a corporation. ...

He [the judge] never asked himself whether there was a connection between the plaintiff's terms of employment and his non-arm's-length relationship with the payer.             ...

However, in a recent judgment this Court undertook to reject that approach, and I take the liberty of citing what I then wrote in this connection in the reasons submitted for the Court:     Francine Légaré v. ...

Arguments [18]     The Respondent's counsel refers to the definition of "tax shelter" in subsection 237.1(1) of the Act, which reads as follows: "tax shelter"- 'tax shelter' means any property in respect of which it may reasonably be considered having regard to statements or representations made or proposed to be made in connection with the property that, if a person were to acquire an interest in the property, at the end of any particular taxation year ending within 4 years after the day on which the interest is acquired, (a)        the total of all amounts each of which is (i)          a loss represented to be deductible in computing income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year or any preceding taxation year, or (ii)                 any other amount represented to be deductible in computing income or taxable income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year or any preceding taxation year, other than any amount included in computing a loss described in subparagraph (i), would exceed (b)        the amount, if any, by which (i) the cost to the person of the interest in the property at the end of the particular year, would exceed (ii) the total of all amounts each of which is the amount of any prescribed benefit that is expected to be received or enjoyed directly or indirectly in respect of the interest in the property, by the person or another person with whom the person does not deal at arm's length but does include property that is a flow-through share or a prescribed property. [19]     Counsel argued that in Appellant Labelle's case, the loss that was pronounced as deductible in computing the income was in the amount of $20,003, and in Appellant Thivierge's case, it was $8,001. ...

Langelier allows us to establish a connection between the date on which the receipts were given and the receipt numbers. ...

Ross, certified that all the work in connection with the Dominion Bureau of Statistics, which totalled some $6,000,000, had been completed by the prime contractor according to plans and specifications; and that no holdback was to be retained. ...

Sexton J.A. did not deal with the elaborate operational infrastructure of Precision Gutters since that was considered to have been a separate business whose breadth and level of responsibility and financial connection with the end user was distinct from the business aspect of the installation process- in the narrow sense- as it applied to the installers ...

The main argument was that this amount had been posted as expenses for the appellant and as income for the new company. [38]     This argument was not very convincing, especially since it is difficult to imagine that a new company would have earned revenues from prospecting and making studies and analyses before or at the point of being incorporated. [39]     Was this amount spent to generate profits or benefits for the appellant in connection with her economic objective? ...

This was referred to as a management fee and was to be "... inclusive of all taxes, of whatsoever nature and kind, including without limitation, the Goods and Services Tax pursuant to the Excise Tax Act (Canada), which may be payable in connection with such fee by the Association". ...