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Bellfield can be considered a pioneer. [10]   According to the testimony of certain individuals, some believed that Mr. ... Canada, [24] the Federal Court of Appeal considered the deductibility of expenses that the taxpayer paid to an agent in efforts to sell certain precious gems. ... Canada, [60] the Supreme Court of Canada considered the proper inquiry for the income-earning purpose test under subparagraph 20(1)(c)(i). ...

That paragraph reads as follows:   [85]      It may be useful at this stage to summarize the principles of corporate and taxation law considered in this appeal, in light of their importance.  ...   (4)        Documents other than the share register, the constating documents, and any unanimous shareholder agreement are not generally to be considered for this purpose ... A corporation the voting shares of which are distributed among a large number of persons is usually not considered to be controlled by any group of its shareholders, provided the shareholders do not act together to exercise control. ...

A I considered it, but in short of having something to support it, what was I going to do? ... Taken at its most anodyne, this description of his activities could reasonably be considered part of the corporate management services Longview was able to provide. [154]    Mr. ... In your opinion, what are the appropriate data and economic factors to be considered when determining what an arm's length person, standing in the shoes of [the Appellant], would have agreed to pay for the services described below [in the Factual Assumptions provided to Mr. ...

As such, on January 6, 2025, the Court issued a Confidential Judgment and Reasons, which afforded the parties an opportunity to propose any redactions that they considered appropriate for the public version of the decision, to be issued subsequently. In letters dated January 13, 2025, each party proposed redactions to protect information that it considered commercially sensitive. ... In that case, the Federal Court of Appeal [FCA] considered a decision of the Tax Court in which the taxpayer did not call his accountant or his bookkeeper as a witness. ...

" 22 In my view, the paintings purchased by the taxpayers that were purchased with an intention to donate cannot be considered to be purchased with a legitimate intention of gaining a profit. ... Certainly, without the advantage of having seen and heard the witnesses, we are not in the position to say that he wrongly rejected the evidence of any one [...] nor could we [...] substitute our view of value for his. [40]      In this case, the Tax Court judge considered each expert"s appraisal methods, and concluded that no one method was satisfying. ...

I agree that, in deciding whether or not any activity may be classed as a business under the provisions of s. 7(1)(b) of The Assessment Act, all relevant factors regarding an operation must be considered and weighed. However, they must be considered and weighed in order to determine not whether in some general sense the operation is of a commercial nature or has certain commercial attributes, but whether it has as its preponderant purpose the making of a profit. ...

Her finding was confirmed by the advance rulings directorate after it considered the parties’ representations.   ... Analysis   [23]          Subsection 256(2.1) of the ITA provides as follows:   (2.1) Anti-avoidance ― For the purposes of this Act, where, in the case of two or more corporations, it may reasonably be considered that one of the main reasons for the separate existence of those corporations in a taxation year is to reduce the amount of taxes that would otherwise be payable under this Act or to increase the amount of refundable investment tax credit under section 127.1, the two or more corporations shall be deemed to be associated with each other in the year ...

Glegg indicated he considered himself and his holding company to be one and the same. ... Barrett’s evidence, that the Tax Court’s decision in Fortino was not considered, and Mr. ...

It does cut the Gordian knot by creating distinctions between dependent and non-dependent children, the former being included in the family unit and receiving their refundable tax credit through that channel, the latter being considered, as any other unattached individual, a tax unit on its own and receiving the tax credit personally. ... In my view, issues relating to policy objectives and legislative intent should not be considered at the initial stage of Charter analysis (i.e., the inquiry into whether there is, in fact, a breach.) ...

That case involved determining the percentage of the distance driven by a taxpayer in connection with his employment under subsection 6(2) of the Income Tax Act (ITA), and he decided that 85% could be considered "all or substantially all". ... The Queen, 2003 TCC 791, Justice Sheridan found that 81% of the distance driven in the course of employment could be considered "all or substantially all" of the distance travelled in the course of employment for the purposes of the ITA. ...