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  [36]            Among the publications he read on this point, he noted one published by Ross Skinner in 1972, a Canadian author who the judge mistakenly considered was American. ...

  [13]          The purchase of term deposits cannot, in my opinion, be considered a deductible expense in this case, under paragraph 18(1)(a) of the Act, even if these term deposits were mortgaged in favour of the Bank and the appellant temporarily lost enjoyment. ...

The assessor considered whether to apply the late and unlamented REOP principle, (which has been given a decent burial by the Supreme Court of Canada). ...

At that time, the Appellant was reassessed for unremitted source deductions for certain family members who were not considered to be employees but whom the Canada Revenue Agency determined were employees. ...

Those documents do not clearly state whether the parties considered the transaction to be a sale of a separate business or simply a sale of a number of assets. ...

Analysis I have considered the evidence in this case and have concluded that in the absence of information acquired subsequent to the financial statement date, a reasonable estimate of contingent profit commissions could not be made by Stevenson & Hunt at the financial year end. ...

In order to obtain what it considered to be a fair compensation (which the learned trial judge has found, on ample evidence, to have been the appellant’s primary purpose) it was necessary to seek to set the legislation aside. ...

Furthermore, the Minister considered that Class 29 of Schedule II of the Income Tax Regulations (Regulations) did not include artificial snowmaking equipment and that that equipment did not constitute qualified property within the meaning of subsection 127(9) of the Act. ...

  [7]               Because of this conclusion several cases submitted by respondent's counsel need not be considered: Inco Limited v. ...

Livingston, 2008 DTC 6233, Justice Sexton of the Federal Court of Appeal laid down the criteria of application of section 160 in connection with the purpose and spirit of subsection 160(1):   [9] The   Tax Court Judge   determined that in order for subsection 160(1) of the Act to apply, the following four criteria must be met:   1)             There must be a transfer of property;   2)      The parties must not be dealing at arm's length;   3)      There must be no consideration or inadequate consideration flowing from the transferee to the transferor (I would note that the trial judge considered the test to be “No consideration or inadequate consideration flowing from the   transferor   to the   transferee ” [emphasis added]: this is a mistaken quotation of the test as cited in   Raphael v. ...