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Expense- Shareholder Assistance The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

The Minister disallowed all the taxpayer's business deductions in connection with the franchise, on the basis that there was no business activity, and that the franchise and note were shams entered into predominantly for tax reasons. ...

Repairs or Running Expense In finding that costs incurred by the taxpayers, who in partnership carried on a business of distributing Amway products in Canada, in connection with attending conventions in the U.S., would have been non-deductible in the absence of s. 20(10), MacKay J. stated: "I do not doubt that the plaintiffs believe they acquired awareness of how others had been successful and even techniques useful in motivating others to participate and to succeed in the Amway network. ...

However, it was found that they were not "tangible property attached to a building" for purposes of paragraph (b) of Class 8 because "the words 'attached' in the English language version of clause (b)(ii) means more than a mere connection; the tangible property must be so attached to the building that it more or less becomes part of it" (p. 1862). ...

However, it was found that they were not "tangible property attached to a building" for purposes of paragraph (b) of Class 8 because "the words 'attached' in the English language version of clause (b)(ii) means more than a mere connection; the tangible property must be so attached to the building that it more or less becomes part of it" (p. 1862). ...

The Queen, 2008 TCC 62-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) mere error is insufficient The failure of the taxpayer to include in his income the reimbursement by a corporation of expenses incurred by him in connection with a criminal prosecution of him did not permit the Minister to assess the year in question beyond the statute-barring period, given that the correct treatment of such reimbursements was by no means clear. ...

Profit- Commodities, and commodities futures and derivatives large purchase of toilet paper at profitable price The taxpayer, a businessman with many interests (lending money, the film business, and dealing in real property) happened to be in Berlin in connection with those interests and had the opportunity of making a purchase of a very large quantity of toilet paper from a bankrupt German firm for less than 10% of the amount for which he was ultimately able to sell the toilet paper to a British purchaser. ...

Mina and Jacobi, 88 DTC 6245, [1988] 1 CTC 380 (FCTD)-- summary under Subparagraph 8(1)(h)(ii) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h)- Subparagraph 8(1)(h)(ii) Educational consultants employed by the North York Board of Education were entitled to deduct automobile expenses incurred by them in connection with making frequent daily trips between five schools and their office location in light of evidence that although lack of a car would not immediately lead to termination, termination would follow if the employee's job function were impaired. ...

Regarding the taxpayer's submission that it had reasonable grounds to believe that no taxes were owed in connection with the late-filed returns, Hogan J. stated: To succeed with this defence, the taxpayer must show how the error was made and demonstrate that he relied on the error in deciding to postpone the filing of the returns beyond their due date. ...

This profit was found to be realized in connection with an adventure in the nature of trade given that those debentures could not be considered to have been acquired for income and given that the profit arose at least in part from his efforts as a businessman. ...