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It is the actual legal situation which must be considered unless the legislation regarding tax avoidance in Part XVI of the Act is alleged, which is not the case here. ...

., as he then was, considered the concept of “sham” in Canadian law. He made the following observations: 57 However, courts have always felt authorized to intervene when confronted with what can properly be labelled as a sham. ...

The general pattern of Jacob and Max Borinsky in acquiring properties and retaining them for income purposes is also a factor to be considered. ...

The alternative argument could only be considered by this Court if the respondent had successfully established that Mrs.  ...

I do not indicate which way it ought to be, but I commend the Commissioners to consider what took place in the nature of organizing the speculation, maturing the property, and disposing of the property, and when they have considered all that, to say whether they think it was an adventure in the nature of trade or not.   ...

Its relevance is only as evidence of the carefully considered efforts that were being made to resolve the differences. ...

The source of the unexplained funds could not be related to a non-taxable transaction and the funds were therefore considered to be taxable income as the most likely source was to be from the sale of narcotics. ...

As late as May 13, 1974 a letter from the commissioner, J JG Gaudaur to Mr R J Sazio, president of the Football Club points out that these transfers as well as what he refers to as the proposed transfer of 5,100 shares from Mr DeGroote to Pine Hollow Holdings Limited must be approved by the commissioner or executive committee before the transfer can be considered effective. ...

Rankin, and the changes in American tax law had a negative and unexpected impact on the business, no evidence was presented to show what profit the taxpayer might have earned had these events not occurred and whether the amount would have been considered substantial when compared to his professional income. ...

The plaintiff is a company which was incorporated pursuant to the laws of Saskatchewan, on February 6, 1959, having the following restricted objects: (a) To acquire land and any other property in the South-Eastern Section of the City of Regina, in the Province of Saskatchewan, or elsewhere in the City of Regina, for the purpose of Community Shopping Centre or Centres; (b) To develop a community shopping centre or centres in the City of Regina and for that purpose to construct, build, improve, lease, rent, control, develop and manage all and every kind of building, structure, shop, store, office, premises, plant, service station and any other business or other premises of all or any kind which may be considered conclusive or incidental to the development or benefit of any such shopping centre. ...