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Davies J stated (at para. 143): [T]he CRA and MNR effectively approbated and reprobated the same conduct by the Appellant and thereby reached inconsistent decisions by failing to apply the same considerations and deemed facts to both applications. ...

The Queen, 2015 DTC 1141 [at at 908], 2015 TCC 146-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing inducement payments received by lessor from manufacturer not income until potential repayment obligation quantified General Motors of Canada Limited ("GMC") made "residual value support payments" to the taxpayer ("GMAC"), which purchased vehicles subject to leases, in consideration for GMAC increasing the residual values (thereby reducing lease payments). ...

Bisson, 72 DTC 6374 (FCTD)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) The taxpayer, who was the general manager and one of the two principal shareholders of a bus company ("Hull City Transport") agreed, in settlement of a dispute with the other principal shareholder ("Thorn"), to purchase the beneficial ownership of the shares of Thorn in consideration for annual payments of $3,000 for four years, and $5,000 per year thereafter until the sum of $60,000 had been fully paid. ...

The Queen, 86 DTC 6264, [1986] 1 CTC 507 (FCTD), aff'd 88 DTC 6522, [1988] 2 CTC 365 (FCA)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) JV company at arm's length with 50% shareholder Since the taxpayer was held to be dealing at arm's length with a corporation ("Clarebeau") 1/2 of whose shares were owned by the taxpayer's family holding company and 1/2 of whose shares were owned by the family holding company of his business associate ("Claridge"), a sale by the taxpayer of share purchase options to Clarebeau for nominal consideration was governed by s. 7(1)(b) rather than s. 7(1)(c). ...

Robertson JA affirmed the Minister's opinion that the $50 "fines" were consideration for a taxable supply- the provision of parking services. ...

Dreyfus [1906] 1 KB 584 at 589) but would also include one who lends money on a regular and continuous basis over time to a limited group of borrowers for an arm's length consideration (see in particular the extended meaning of the word "business" in par. 248(1)). ...

Tallon is to be deprived of the benefit of the prior decision for a subsequent year, it is only fair to her that the Court give careful consideration to the reasons in the prior case. ...

"The premiums are part of the consideration given by the borrowers for the use of the capital lent to them, and part of 'the creditor's share of the profit which the borrower... is presumed to make from the use of the money'. ...

The Queen, 89 DTC 5458, [1989] 2 CTC 284 (FCTD)-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 bonus amounts to family members were completely disproportionate to services rendered Accrued remuneration incurred by a family-owned corporation for two weeks per year of work at the store by the wife of one of the minority shareholders (of $50,000 per annum for the 1982 to 1984 taxation years of the corporation) and for one month's work each year by each of her four children (ranging from $12,500 to $20,000 for those taxation years) was found to be "completely out of proportion to what others receive for working in the store", and the deductible amount was reduced, taking into account the countervailing consideration that "it is not reasonable to limit their remuneration to what was paid to non-family members". ...

In response to the taxpayers' submission that too much time had passed between the different transactions for them to be one series of transactions, Trudel JA noted (at paras. 17-19) that Copthorne indicated that sometimes the elapsed time would be a relevant factor in this determination, and that Boyle J had made a finding of fact that, at the time the decision was taken to pay a capital dividend, New Supervac had taken into consideration the capital dividend account that had been acquired with the Old Supervac shares. ...