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However, in each case, Royal Trust…reviewed the Trust document to ensure that the proposed approval was within its authority and then considered whether there were any negative consequences for the beneficiaries" (para. 34). ...

The principle of corporate non-consolidation, set out in para. 97 of Copthorne, requires that each corporation's tax liability be considered independently (para. 47). ...

After noting that in MRT, ESG and Rockmore, 75 DTC 5224, aff'd 76 DTC 6156 "Walsh J. considered that each of the taxpayers were making loans to high-risk borrowers, investigated potential borrowers carefully, and negotiated extensively over terms, indicating that an active business of moneylending was being carried on" (para. 40), Rip J stated (at para. 42): All three corporations operated on a very small scale, with Rockmore, for example, holding only three loans in 1972. ...

Mainville J.A. stated (at paras. 5-6): Whereas business goodwill was formerly considered to pertain to good name, reputation and connection principally with respect to customer relations, the concept has now taken on a broader meaning influenced by economic, accounting and valuation theories. ...

Strayer D.J. found that the requirements of promissory estoppel existed (on the basis of a "promise" provided in the Information Circular that a disclosure will be treated as voluntary if the client initiates it, subject to it being considered involuntary if the client initiates the disclosure with the knowledge of an audit, investigation etc. by the CCRA or an authority with which CCRA had an information exchange agreement) and on the basis that the taxpayers had no knowledge that the police force was such an authority with which CCRA had an information exchange agreement (even if the informal arrangement between that police force and CCRA could be described as a qualifying agreement). ...

[emphasis in original] Taylor T.C.J. considered himself to be bound to choose only as between the two change-of-use dates advanced by the two parties, being January 1, 1973 and May 28, 1975, and indicated (at p. 1853) that the latter date was “a more acceptable date.” ...

The donation issue was common to several files, and the Minister indicated that the objection would be considered after the common issue was resolved. ...

As a preliminary matter, C Miller J found that terminal and jetty were one asset on the basis that the Jetty could "be considered ancillary and necessary, and part of the integral totality of the operation occurring at the Terminal" (para. 88), including that the jetty operators monitored the safety of the overall operation. ...

Zhang as purported additional consideration for the transfer, a joint s. 85(1) election was filed and a rectification order was sought to have the share issue be considered to have occurred on the date of the transfer. ...

The Minister considered that the Fund obligations to pay the Management Fee Distributions to the large investors was part of the consideration that the Funds provided in exchange for the appellant's services, and assessed the appellant for failure to charge GST on the gross amounts. ...