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The applicable Social Service Tax Act (B.C.) provision required that tax be paid on the “lease price” of leased property which was defined to mean the “total consideration paid…for the right to use the leased property”. ...

Malone, J.A. concluded that the appellant was making taxable supplies of insurance, fuel, oil and licences to the owner-operators, stating that "[t]he uncontradicted evidence... is that valid consideration flowed from the owner-operators to Vanex. ...

., transferred the shares of its subsidiary ("CAHL"), which was non-resident in Canada notwithstanding that it had been incorporated in Canada in 1929, to a newly incorporated Canadian-subsidiary of Products ("Holdings") in consideration for a common share of Holdings that had a paid-up capital equal to the fair market value of CAHL. ...

The King, 2023 TCC 156, aff'd 2025 FCA 175-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit no evidence to call into question the underlying assumption in Stewart that the taxpayer pursued her clearly-commercial farming venture for profit Before going on to find that the taxpayer’s losses from a cattle operation (which were substantial both in dollar terms and relative to the revenues) were deductible as business losses before consideration of the limitation on farming-loss deductions under s. 31, Owen J stated (at paras. 103-105): The assumption underlying the test in Stewart is that a commercial activity is undertaken for profit… Consequently, unless there is some reason to question this assumption in the circumstances of a particular case, an activity that is on its face clearly a commercial activity as opposed to a personal undertaking is considered a source of income. ...

Profit- Shares different administrative treatment of share and land transactions may be based on pragmatic considerations/ here there was a concerted activity that was a business, not an adventure The taxpayer, who in 2001 had made 151 purchases of stock in 16 companies, which were held for short periods of time, was found to be engaged in a business in the ordinary sense of the word with respect to his trading activities, with the result that the losses he sustained were on income account. ...