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Minister of National Revenue, [5] Rouleau J. made reference to: the nature of the property sold; length of period of ownership; frequency of similar transactions; the work expended in connection with the property realized; the circumstances responsible for the sale of the property; the taxpayer’s intention at the time of acquisition of the asset. ...

Separate Reasons for Judgment in connection with the three corporate Appellants (the “Corporate Appeals”) were rendered on June 24, 2021 (2021 TCC 42). [2] This matter addresses costs and considers the written submissions of the parties. ...

(“Happy Valley Farms”) (para. 18) including 1) the nature of the property sold; 2) the length of period of ownership; 3) the frequency or number of other similar transactions by the taxpayer; 4) work expended on or in connection with the property realized; 5) the circumstances that were responsible for the sale of the property; and 6) the motive for selling. ...

.- all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (vii.l) reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment, The Minister made mention of paragraph 18(1) in the Reply to the Notice of Appeal. ...

In connection with the application he made to the CPTAQ in 1984 for the permit to build his residence, the appellant described his objectives as follows (at p. 2 of Exhibit A-1): [TRANSLATION] Development Project (L506/R3726/T2/BT2) test_linespace (240>217.60) 0.847 0965_4803_4937 We have sufficient resources that will enable us to meet the following schedule: Short term: (0- 2 years) • preparing soil and sowing; ¢ application of soil enhancers and fertilizers; ¢ application of pesticides and herbicides: ° construction of fences. ...

Here, we do not have this intimate connection. The closest reserve, the Dakota Ojibway reserve, was 100 kilometres away from Winnipeg, while the furthest away, the Keewatin reserve, was located so far north that an overnight airplane trip was required to get to Winnipeg. ...

Canadian Investment Fund (CIF) The CIF is intended to identify the dollar value of the pool of property that is considered to be used or held in connection with the Canadian business of the insurer. 4 4In the transcript of his evidence, from pages 106 to 109. 5 55 % management fee x GWLP receivable from GWL of $49,709,601 = $248,548. 6 The interest calculation on a demand note of $124,500,000 issued by GWLP to GWL in December 1988. ...

If that had been the case, a connection by marriage could not have been established between Mr. ...

Securities of Company to be Acquired: Buyer will purchase all of Seller's common shares representing the real and personal property of Canadian Pizza Crust Company Limited (Company) including Company's corporate name, trade names, trademarks, formulas, trade secrets, rights under licenses, contract rights, books and records, equipment and real property leases, accounts receivable, inventories, and all other assets of Company used in connection with its business. ...

We understand that paragraph 8(1)(g) allows a deduction, specifically, in connection with the work done in the transport sector. ...