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The predecessor of s. 78(1) accordingly did not apply to a non-arm's length sale of land inventory for a consideration to be paid over a 7-year period. ...

The provision for the payment of such compound interest was "part of the consideration promised by the appellant in order to secure its capital. ...

Canada, [1998] 1 S.C.R. 795, 98 DTC 6334, [1998] 3 CTC 303-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance no business purpose test In finding that the transactions under consideration had successfully avoided the change-of-control provisions of the Act, Iacobucci C.J. stated (at p. 6350) that "it is well established in the jurisprudence of this Court that no 'business purpose' is required for a transaction to be considered valid under the Income Tax Act, and that a taxpayer is entitled to take advantage of the Act even where a transaction is motivated solely by the minimization of tax". ...

Canada, 99 DTC 5799, [1999] 3 S.C.R. 804-- summary under Public Policy Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Public Policy In finding that considerations of public policy should not enter into a determination as to whether fines or penalties were deductible in computing income, Iacobucci J. stated (at p. 5811) that doing so would "place a high burden on the taxpayer who is to engage in this analysis in filling out his or her income tax return and would appear to undermine the objective of self-assessment underlying our tax system". ...

Minister of National Revenue, 49 DTC 514, [1949] CTC 1, [1949] S.C.R. 287, [1949-1950] DTC 514-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) guarantee payments not interest In finding that annual amounts described in various resolutions of the taxpayer as "interest" in fact were guarantee payments, Locke J. stated (p. 515): "Interest is paid by a borrower to a lender: a sum paid to a third person as the consideration for guaranteeing a loan cannot be so described. ...

Fries, 90 DTC 6662, [1990] 2 S.C.R. 1322, [1990] 2 CTC 439-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) payment from union to support another strike was non-taxable Amounts received by an employee of the Saskatchewan Liquor Board from the Saskatchewan Government Employees' Union (the "SGEU") in consideration of his agreement in support of a strike by government employees who were not Liquor Board employees, to withdraw his services from the Liquor Board, were not taxable to him as income from a source. ...

., 57 DTC 1017, [1957] CTC 1 (Ex Ct)-- summary under Accounting Principles Summary Under Tax Topics- Income Tax Act- Section 9- Accounting Principles Before agreeing with the accounting experts that the taxpayer's instalment method of accounting for its sales of magazines was more appropriate than the accrual method which underlaid the Minister's reassessments, Thorson P. stated (p. 1026): "The prime consideration, where there is a dispute about a system of accounting, is, in the first place, whether it is appropriate to the business to which it is applied and tells the truth about the taxpayer's income position and, if that condition is satisfied, whether there is any prohibition in the governing income tax law against its use. ...

The question at this stage is whether the taxpayer can establish an intention to make a profit, whether or not he was motivated by tax considerations". ...

Minister of National Revenue, 70 DTC 6366, [1970] CTC 572, [1971] S.C.R. 601-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Proceeds of Disposition proceeds of disposition not reduced to reflect that debentures received had a lower FMV that their principal amount In rejecting an argument that recapture of depreciation should be reduced to reflect the fair market value of debentures received in consideration for the depreciable property being lower than their principal amount, Pigeon J. noted that s. 20(5)(c) of the pre-1972 Act deemed proceeds of disposition of the property to include the sale price, which was equal to the principal amount of the debentures. ...

Minister of National Revenue, 70 DTC 6366, [1970] CTC 572, [1971] S.C.R. 601-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition- Paragraph (a) proceeds of disposition based on face amount rather than FMV of debentures received therefor In finding that recapture of depreciation should not be reduced to reflect that the fair market value of debentures received in consideration for the depreciable property was lower than their principal amount, Pigeon J. noted that s. 20(5)(c) of the pre-1972 Act deemed proceeds of disposition of the property to include the sale price, which was equal to the principal amount of the debentures. ...