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In my view, however, even if it could properly be said that the residence of the appellant was throughout the period from November 23, 1941, to May 8, 1946, extraordinary, in the sense of being out of the usual course of his life considered as a whole, it would not follow that he had during such period an ordinary residence in Canada; it would rather follow that during the years mentioned he ceased to have anywhere a residence which was ordinary in the corresponding sense. ...

What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being—Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making?” ...

As to the alternative submission (which Lord Thankerton stated was not seriously pressed), it seems clear that the amount remitted was properly considered as a capital item. ...

This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income—including payment of a tax under the provisions of Section 105B of the Act—had been weighed and rejected. ...

.:   While in the sense identified by the majority, subsection 160(1) may be considered a harsh collection remedy, it is also narrowly targeted.  ...

Ford apparently controlled the operations of the company and as the anticipated cost of drilling the well on the farmout in question was about $55,000 he considered this was too big an investment for the company and, accordingly, sold the half interest to the Reality Company for the sum of $27,500. ...

He cited a number of cases dealing with the sale of partnership interests in which it had been held that the proceeds of the sales were to be considered as capital and not as income. ...

I agree that the meaning of the word “structure” must be determined in relation to its use in the paragraph in question here, but I think it is proper to consider what has been considered to be a structure in connection with other taxing statutes. ...

She very carefully considered and reviewed in detail the complex and conflicting expert evidence.  ...

The Honourable the Minister of National Revenue, having duly considered the facts as set forth in the Notices of appeal and matters thereto relating, hereby affirms the said assessments appealed against on the ground that the Executor of the estate has been properly assessed upon the income accumulating in his hands in trust for the benefit of unascertained persons or persons with contingent interests, irrespective of whether such unascertained persons or persons with contingent interests are or may be in the future resident in Canada or outside of Canada. ...