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The Queen, 88 DTC 6138, [1988] 1 CTC 263 (FCTD), aff'd 91 DTC 5106 (FCA)-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership Although ownership of oil was found to shift, at the ship's permanent home connections at the loading port, almost simultaneously from the supplier to a Bermudan company ("Irvcal"), and from Irvcal to the taxpayer, the ownership of Irvcal of the oil for that instant of time was recognized. ...

The Queen, 93 DTC 5412, [1993] 2 CTC 173 (FCTD)-- summary under Paragraph 8(1)(b) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(b) Legal expenses (but not interest thereon) paid by a dismissed member of the Alberta Union of Public Employees in connection with a grievance before an arbitration board resulting in his reinstatement were deductible. ...

More generally, these activities were performed directly in connection with manufacturing or processing of newspapers for sale. ...

., 77 DTC 5091, [1977] CTC 151 (FCTD)-- summary under Loans and Financing Charges Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Loans and Financing Charges A fee of $61,317 which a subsidiary paid to its parent for services that the parent (primarily in the person of its shareholder and officer) performed in connection with taking the parent public so as to obtain funds to expand the subsidiary's business, was found to be deductible. ...

Canada, 2003 DTC 5744, 2003 FCA 458-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit The Tax Court had correctly found that the taxpayer, who worked as a full-time employee, was not using his residence in connection with an auto sales business. ...

The Queen, 88 DTC 6212, [1988] 1 CTC 336 (FCTD)-- summary under Subsection 18(2) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(2) Interest and taxes were non-deductible under the pre-1978 version of the provision both because the land in question was held for ultimate subdivision or development, and because land held as an adventure in the nature of trade is not held in connection with carrying on a business. ...

The Queen, 2005 DTC 959, 2005 TCC 335-- summary under Price Adjustment Clause Summary Under Tax Topics- General Concepts- Price Adjustment Clause The existence of an "anti-flip agreement" allegedly given by the taxpayer in connection with its purchase of shares (under which it would pay to the vendor any consideration received by it, on a subsequent sale by it of the shares, over and above the purchase price) was found not to be supported by the evidence. ...

The length or complexity of a case or the volume of work required in connection therewith are not sufficient factors by themselves to warrant a special direction as to costs under Ruler 344(7)". ...

Because this obligation was assumed in connection with the purchase of a business, the associated payments were non-deductible capital expenditures. ...

Repairs or Running Expense The taxpayer paid $480,900 to the City of Montreal in connection with a land exchange with the City and relocating a city street further to the north. ...