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The Queen, 2015 DTC 1103 [at at 614], 2015 TCC 80 (Informal Procedure)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date consideration for transfer to shareholder adjusted without price adjustment clause An individual shareholder of a corporation ("B&N") thought that he was the beneficial owner of his home, but everyone else, including his accountants (and ultimately the Tax Court) considered that it was beneficially owned by B&N. ...

Neither party had considered the written agreement to have ever been cancelled. ...

Neither party had considered the written agreement to have ever been cancelled. ...

The necessity to determine primary purpose implies that there is more than one purpose and that the transaction is to be considered as a whole. ...

She then found that the above elements (kiosk provision, cashier services and cheque cashing) were "not so interdependent that they should be considered a single supply," it being "convenient, but not necessary, that the Casinos provide all of these elements" (para. 94), and "none of these elements are a minor part of the supply so as to be incidental" for purposes of s. 138 (para. 96). ...

It was reasoned that the mere holding of inventory does not constitute a use of the property for an income-producing purpose in the context of considering a conversion of depreciable property to inventory (or vice versa) – whereas inventory should be considered to be income-producing property in the context of a conversion of personal-use property to inventory, or vice versa. ...

Section 6302 of the Regulations sets out the various factors that are "to be considered in determining what constitutes care and upbringing of a qualified dependant. ...

" Walsh J further stated that even if the value of the lands (net of the first mortgage liability) had been insufficient to pay the amounts (including interest) owing to the appellant, the value of the lands acquired (net of the assumed first mortgage) would be attributed first to interest, with any remaining balance attributed to capital, so that any value shortfall would not have the effect of reducing the amount of interest considered to have been received by the taxpayer under s. 6(1)(b) of the pre-1972 Act. ...

The patrimony tax was not creditable as an income tax or a tax in lieu of an income tax for purposes of s. 131 of the Internal Revenue Code of 1939 because, separately considered, it was really a tax on property and resulted in a levy upon the net value of the taxpayer's assets which would include any unrealized appreciation of such value, it was computed separately from the income tax, and a taxpayer could be liable for patrimony tax in a year in which the taxpayer had no revenue and was not liable for income tax. ...

" He went on to indicate (at p. 153) that under English law, where A and B are the partners in partnership X, and X and another person (C) form another partnership, partnership Y, A and B are considered to be partners in partnership Y in their capacity as members of partnership X. ...