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Flanigan stated (p. 277): "There are literally hundreds of people who are employed by American corporations who come into Canada and do business, but these people are certainly not considered to be Canadian residents or to have a permanent establishment if they attend at an office in this country to transact their business". ...

The ordinary meaning of the word "liable" ("responsible at law"), the contrasting use of the terms "liable" and "payable" in the relevant provisions and the fact that this interpretation was consistent with an interpretation that the enactment of s. 162(2.1) was intended by Parliament to put some teeth into the filing requirements for non-resident corporations, suggested that a corporation would be considered to be "liable to a penalty" under s. 162(1) even if such penalty was nil. ...

The Queen, 78 DTC 6445 as establishing the proposition that "the question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent businessman" and went on to find (at p. 219) that the taxpayer "did not discharge its burden of proving that the debt was not uncollectible in the year 1982 on the balance of probabilities". ...

., in situations where the audit site was further from her home than from the office of her employer) as being of a non-personal nature given that it would be inefficient for her to go to the office and then to the audit site, and no element of the distance covered when she went from her home directly to an audit site should be considered to be of a personal nature. ...

Fordham found (at p. 249) that the "real purpose" of the agreement was to give the taxpayer the sole right to use the Anne Klein name in Canada and that "anything else was... purely incidental and not to be considered as meriting separate terms of payment". ...

Canada (Revenue Agency), 2007 DTC 5527, 2007 SCC 42, [2007] 3 S.C.R. 217-- summary under Expressio Unius est Exclusio Alterius Summary Under Tax Topics- Statutory Interpretation- Expressio Unius est Exclusio Alterius Rothstein J. rejected a submission of the Crown that because Parliament had enacted provisions of the Act respecting registered Canadian amateur athletic associations (RCAAAs), it should be considered to have established that athletic associations could not also qualify as charitable organizations. ...

Canada (Revenue Agency), 2007 DTC 5527, 2007 SCC 42, [2007] 3 S.C.R. 217-- summary under Redundancy/reading in words Summary Under Tax Topics- Statutory Interpretation- Redundancy/reading in words Rothstein J. refused to give an expansive interpretation to what was charitable in the context of a submission that a sports organization should be considered to be charitable in part in light of the consideration that an expansive interpretation would undercut the distinction drawn under the Act between non-profit organizations that were operated exclusively for social welfare, and charitable organizations, and stated (at para. 28): "When courts consider expanding the definition of charity, therefore, they must consider whether what is being proposed is an incremental change, or one with more complex ramifications that is better left to the legislature. ...

Although the U.S. parent was considered to be carrying on a business in Canada, i.e., providing various administrative, supervisory and other services to the taxpayer at cost, the rents received by it could not reasonably be attributed to any part of the business which it carried on in Canada. ...

Hogan J. stated (at para. 16): [T]he real question is whether subparagraph 152(4)(a)(i) applies to a taxation year that is otherwise time-barred when the facts considered incorrect are presented because the taxpayer interpreted the circumstances to favour the non-taxation theory since they fall in the grey zone of tax law. ...

In concluding that the reassessment was not statute-barred, Hogan J. found that the taxpayer's position (that she had realized a capital gain that was eligible for the principal residence exemption) was not unreasonable, and stated (at para. 28): [E]ven if a person occupies a building for a short time, it can be considered his or her principal residence. ...