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While the renovations were extensive (taking three years and $722,505), they were not so extensive that the restored vessel could be considered a new asset (a similar vessel would have cost $2 million new). ...

"It is undeniable that a payment by a corporation, whatever its form, which has the effect of extinguishing a debt or obligation of a shareholder must be considered to be a benefit conferred on him... ...

Canada, 2013 DTC 5074 [at at 5909], 2013 FCA 88-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning context always considered Before rejecting a literal interpretation of ITA s. 146(9) advanced by the Crown, Sharlow JA stated (at para. 59): [A] literal interpretation of a statute cannot be accepted without further examination. ...

The Queen, 83 DTC 5451, [1983] CTC 432 (FCTD)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits It was stated in the context of the Excise Tax Act that the addition of radios by a Canadian distributor to imported motor vehicles "would not, in normal commercial usage, be considered either as an act of manufacture or production". ...

Profit- Patents and Know-How The taxpayer, which was formed for the purpose of acquiring and exploiting patents and licences and which licensed its patent rights to foreign manufacturers, typically with an option on their part to purchase, realized a taxable profit when such an option was exercised, given that such a dealing in patents should be considered to be part of its business. ...

Instead, the words "it may reasonably be considered" placed a substantial onus on the taxpayer to produce some explanation which is objectively reasonable that none of the purposes was to alter the value of a shareholder's interest". ...

Further, it could be seen that the issue of undue delay was considered in the decision not to waive interest and penalties as the decision referred to the complexity of legal issues involved. ...

Canada, [1998] 1 S.C.R. 795, 98 DTC 6334, [1998] 3 CTC 303-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance no business purpose test In finding that the transactions under consideration had successfully avoided the change-of-control provisions of the Act, Iacobucci C.J. stated (at p. 6350) that "it is well established in the jurisprudence of this Court that no 'business purpose' is required for a transaction to be considered valid under the Income Tax Act, and that a taxpayer is entitled to take advantage of the Act even where a transaction is motivated solely by the minimization of tax". ...

., 80 DTC 6207, [1980] CTC 216 (FCTD)-- summary under Paragraph 256(1)(b) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(b) It was stated, obiter, that where the Court has to decide whether two corporations are associated by reason of being controlled by the same persons or same group of persons, who might be complete strangers and not persons all related by blood, it is de facto control that must be considered, i.e., whether control of the two corporations is in fact exercised by the same group. ...

Addy, J. stated: "Where the development of the basic food product still involves the growing process and natural biological changes as opposed to artificially manufactured foods or mere processing, I do not feel that, generally speaking, the activity would be considered by the general public anything other than agricultural in nature". ...