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This aversion however must be tempered in consideration of Lord Tomlin’s fundamental dictum that "Every man is entitled if he can to order his affairs so that the tax attaching under the appropriate acts is less than it would otherwise be". ...

In consideration of the RRSP, Barbara covenants and agrees that she shall convey to the Children all of her right, title and interest in the property located at Beatons Bluff, Lorneville, County of Cumberland more particularly identified by PID No. 25256207 and PID No. 25109943. 10.               ...

Had the companies been closely related persons as that term is defined for GST purposes and had they made the election made under section 156 of the ETA to have supplies made among them treated as having been made for nil consideration, the result would have been quite different ...

., in coming to his conclusion, took into consideration the following factors: The amounts booked as accident and cargo claims were so entered for that year because the specific events leading to the claims had occurred in that year. ...

After extended periods of dis-connectivity and large amounts of changes queued up, how to exchange those changes to other nodes in an environment of infrequent connectivity. [31]         Although the Respondent argued that some of the uncertainties were not technological and that possible available solutions were restricted by budgetary constraints and licensing considerations, the evidence of the Appellant’s witnesses, which was not challenged on cross-examination, demonstrated that it was impossible to resolve the uncertainties, encountered by the Appellant, through routine engineering or standard procedures. ...

Ltd. with respect to nominal share position for each daughter $100 Non-share consideration for shares in Quamco (i.e. promissory note) 138,800 $138,900 Adjusted cost base of shares in Quamco (as adjusted above) (8,400) Reduction in paid-up capital under 84.1(1)(a) (100) Deemed dividend $130,400 25% gross-up (82(1)(b)) 32,600 Additional to income (with benefit of the dividend tax credit in 121) $163,000 30. ...

Subparagraph 40(2)(g)(ii) reads as follows: 40(2) Notwithstanding subsection (1), (g) a taxpayer’s loss, if any, from the disposition of a property, to the extent that it is (ii) a loss from the disposition of a debt or other right to receive an amount, unless the debt or right, as the case may be, was acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income) or as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm’s length, is nil; For the purpose of subparagraph 40(2)(g)(ii) a taxpayer is deemed to have disposed of a debt owing to him at the end of a taxation year in which the debt is established by him to have become a bad debt: subsection 50(1). ...

Indeed, I am inclined to the view that the phrase "carried on an insurance business... in a country other than Canada" is not to be limited by considerations that may or may not be determinative of whether such a business was carried on in Canada. ...

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 ...