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These categories were considered to account for all possible known facts. ...

The learned Trial Judge made the following findings on the evidence adduced: (a) that the Murphy Oil trading arrangement was considered by the parties to be a valid contract and all parties acted upon it pursuant to its terms, at all relevant times, including the taxation year 1970, notwithstanding the Tepwin contract; (b) that Murphy Oil Trading Company, prior to and up to February 1, 1970, did in fact sell crude oil to the appellant at $1.9876 US per barrel under the Murphy Oil Trading arrangement and that this arrangement was never formally or informally abrogated, the learned Trial Judge accordingly concluding that the Murphy Oil Trading arrangement was a valid and subsisting contract; (c) that it was never intended that the officers and directors of Tepwin in Bermuda would exercise management and control of Tepwin’s business in any aspect. ...

I respectfully agree with the conclusion of the learned President that the question of the propriety of the allowances made by the Department for depreciation between the years 1929 and 1945 cannot be considered in the present appeal, which is concerned only with the allowances for the years 1946, 1947 and 1948. ...

Minister of National Revenue 6, the right of the appellant company to charge as a disbursement expenses incurred in redeeming certain of its bonds before maturity and borrowing again at lower rates of interest and less onerous conditions as to payment, these including the payment of premiums on redemption, disbursements on account of exchange, discount to underwriters and legal and other expenses, was considered. ...

In late 1967 Manufacturer’s, Firemen’s and Blackstone considered it advisable to combine the operations of the companies and obtained legal advice as to how to best achieve that desired end. ...

Accordingly if it is determined that he has been appointed to that service by a religious order, the question whether he is in charge of or ministering to a congregation need not be considered. ...

The evidence was that the parties considered the clauses applied only to “itinerant” teachers, such as French teachers, or music teachers, who might have to teach at two or more different schools on a given day. ...

These provisions read as follows:   103(1)              Where the members of a partnership have agreed to share income or loss of the partnership and the principal reason for the agreement may reasonably be considered to be a reduction or postponement of tax payable, the share of each member of the partnership in the income or loss is the amount that is reasonable having regard to all the circumstances, including the proportions in which members have agreed to share profits and losses.   103(1.1)           Where two or more members of a partnership who are not dealing at arm’s length agree to share any income or loss of the partnership and such share is not reasonable in the circumstances, having regard to the capital invested or work performed by its members or such other facts that may be relevant, the share shall be deemed to be the amount that is reasonable in the circumstances.   74.1(2)         If any individual has transferred or lent property directly or indirectly by means of a trust or any other means to or for the benefit of a minor who does not deal with the individual at arm’s length, income or loss from the property is deemed to be income or loss to the individual. ...

The appellant was unable to show how the advances at issue in this case were distinguishable from the advances the Ontario Court of Appeal considered in TCPL. ...

  [37]            As indicated in the excerpt from the Department of Finance Technical Notes reproduced above, where a taxpayer makes a payment under a guarantee of indebtedness of a corporation, the taxpayer will generally be considered to have acquired the rights of the creditor in respect of that indebtedness at the time the payment is made ...