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According to the evidence, no actions of the Appellant during the years in question with respect to these two activities lead the Court to conclude that a business existed at all, without further substantial actions having been taken by the Appellant to put in to place some kind of activity which would at least have enabled the Court to conclude that some income might have been obtained therefrom. [268]        That leaves for consideration by the Court the more difficult and substantial issue with respect to the expenses claimed in relation to the fishing activity, which undoubtedly was a business during the years in question. [269]        The point raised by counsel for the Respondent that it is the Appellant's duty to keep accurate records of his income and expenses under the provisions of section 230 of the Act is well taken. ... It would be extremely unjust, as far as this Court is concerned, for the Minister to assign to the Appellant all of the income that he did and not give further consideration to the deductibility of many of these expenses, which were obviously expended for the purpose of gaining or producing income from a business. [285]        The appeals are allowed and the matters are referred back to the Minister for reassessment and reconsideration based upon the Court's finding, that on the balance of probabilities, the Appellant is entitled to claim the following further deductions during the years in question. [286]        For the taxation year 1988, vessel repairs, $11,776 crew share $21,063; for the taxation 1989, vessel repairs $100,065, crew share $22,826, food $3,637. ...

These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ...

The argument of counsel for the Appellant on this issue, although ingenious, is rejected. [147] That leaves for consideration the issue of the violation of the provisions of subsection 152(4) by the Appellant. ...

Accordingly, we assume that it should be possible to achieve a grade of 0.20 oz Au/ton, and applied that grade to all of the reserves used in our projections. [25]     WGM relied for its primary valuation considerations on the calculation of Net Present Value ("NPV") based on discounted cash flow ("DCF") projections. ...

To determine if AIL’s business is being carried on from the fixed place of business, the following factors should be considered:  -                      use of premises by AIL-                      control by AIL over premises-                      legal right to exercise control over premises-                      degree to which premises identified with AIL business-                      who paid for expenses of premises-                      who paid for equipment used at premises-                      who made management decisions-                      what contracts were concluded from premises-                      what AIL products were kept on premises-                      did AIL have any Canadian employees-                      who bore the risk of the operation from premises-                      how many principals were represented by the agent-                      were agents subject to detailed instructions or comprehensive control [48]     Respondent’s counsel stressed the concept of integration, though apart from the case of Panther Oil, this does not appear to be a consideration, let alone a determinative factor. [49]     All agents work from a place, whether a PGA’s office or the agent’s home office, that meets the criteria of a place of business and one of permanence. ...

The appellant made a commercial and business decision, after careful consideration, to enter into the swaps in order to protect its consolidated group equity. ...

Persons must have confidence in government because, among other things, they rely on government. [75]         The consideration Revenu Québec gives to applications for GST registration numbers troubles me. ...

That case dealt with an assessment made under section 160 of the Income Tax Act, which renders a non-arm's length recipient of a gratuitous transfer of property from a delinquent taxpayer liable, jointly and severally with the transferor, for the transferor's tax liability, up to a limit defined as the lesser of the extent to which the value of the property transferred exceeds the value of any consideration that may have been given for it, and the total of all amounts each of which is an amount that the transferor is liable to pay under this Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year. [11] It was the latter expression that applied in that case. ...

Adjustments to the 2001 taxation year of $244,525.04 net of increases to the Appellant’s net worth in the year 2000 of $29,352.70, effectively reduce the Appellant’s assessed income by $215,172.34, to approximately $5,423 before taking into consideration the conceded adjustments for china gifts of $2,269 and other minor personal expenditures that were the subject of disagreement between the parties. ...

A   Well, the – the tax shelter position was developed starting at this time and forward for – for – as a consideration for all the arrangements, including the Union CAL trading joint venture.   197. ...