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In cross-examination he agreed that there was a different set of considerations for deductibility under the Income Tax Act, (the Act) and the preparation of the consolidated statement but he concluded that it was a contingent liability and that it would not be paid even if there was a so-called “legal obligation” to pay the interest. ...

It merely recognizes, from a common sense point of view, that inherent probabilities are a necessary consideration in determining what the facts are on a balance of probabilities basis: In re B (Children), [2008] UKHL 35 ...

No single consideration will allow the Court to arrive at the answer because the meaning ascribed to the term in another statute does not mean that the legislators intended to adopt that meaning under the Act unless they specifically said so. ...

These are the appeals presently under consideration. Counsel for both parties tendered as evidence a joint book of documents containing, inter alia, copies of contracts between the appellant and various oil and gas companies and invoices arising out of the implementation of the provisions of those contracts. ...

It would include any consideration given in the performance of any ordinary commercial contract, as well as all those activities more specifically called services, which do not actually involve the production or processing of goods, for instance, banking and financing, transportation, and insurance. [28]          The appellants argued that Marco was a producer and as such did not render services. ...

In my opinion this is the meaning of the word ‘interest’ in the enactment under consideration, and, where one company stands in such a relationship to another, the former can properly be said to have a controlling interest in the latter.. ...

The phrase “to reduce the amount of taxes that would otherwise be payable under this Act’’ refers to the tax which would have been payable if the companies under consideration had not had a separate existence; in the circumstances of this case it must refer to the tax which would have been payable had the appellant either employed its own mechanics and owned its own premises, or had an associated company do so. ...

Finally, there is the consideration that to permit the deductions as claimed tends to distort the computation of the appellant’s income for the years in question, a result which I do not think the language used should be presumed to intend and which should be avoided if the statute can be so interpreted. ...

., [2012] OJ No. 5867 applied the principle in Reliable and in the later case the Court agreed with Master Haberman’s characterization of the provisions under consideration. [21]         1455257 argued that the appeal of the assessment issued against it, constitutes a defence in accordance with paragraph 242(1)(b) “as if the corporation had not been dissolved” and revival was unnecessary. [22]         It relied on the decision of 460354 Ontario Inc. v Her Majesty the Queen, 92 DTC 6534 (FCTD), in which the Court held that the right to take advantage of an appeal procedure in the context of an administrative proceeding (the assessment) must be available to a dissolved corporation by virtue of the statute which authorizes the action. 460354 had voluntarily dissolved and challenged reassessments issued following its dissolution. ...

The defendants continue to reside on the remaining 0.7 acre plus an adjacent 0.225 acre transferred to them by the City as part of the consideration for the 9.3 acres. ...