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These circumstances must be taken into account, but must be considered against an objective “reasonably prudent person” standard.   ...

Chief Justice Rip considered whether privilege attached to four types of communications between a lawyer and others. ...

It was held that an amendment to section 83 of the Income Tax Act applied because it did not operate retrospectively but merely provided that for future years the new rules should apply. [8]               The press release announcing the changes to section 10 stated:                 In circumstances where a taxpayer has claimed an inventory write-down for property held as an adventure in the nature of trade for a taxation year ending on or before today, the amount reported as the fair market value of the property (or such revised amount as determined on assessment or reassessment by Revenue Canada) will be considered to be the taxpayer’s cost of the property for the purposes of computing any income or loss that may be realized in the future. [9]               Intertan Canada Ltd. v. ...

But no one, not even William, considered that any of the issued shares belonged to William. ...

  [4]      The only issue in this case is whether the management fees that the four Appellant corporations paid to a related corporation should be considered part of the four corporations' cost of labour when calculating that cost for the purpose of  determining their manufacturing and processing profits ...

    [49]          Finally, the appellant is seeking to add some invoices that were not considered at the time of his audit. ...

I have considered the Appellant's claim with respect to "chief source of income" by applying the three-pronged test from Moldowan as if there were no issue concerning proof of payment. ...

Thurlow, J found that the payment was a capital receipt in the hands of the appellant and in so finding at page 187 [244, 1154] made the following observations: On the whole therefore having regard to the importance of the Doulton agency in the appellant’s business, the length of time the relationship had subsisted, the extent to which the appellant’s business was affected by its loss both in decreased sales and by reason of its inability to replace it with anything equivalent, to the fact that two of the appellant’s employees became employees of the Doulton subsidiary on the termination of the relationship and the fact that from that time the appellant was in fact out of that part of its business, both as an agent and as a wholesale dealer and particularly to the nature of the claim asserted in respect of which the payment was made, I am of the opinion that, except in so far as it was a consideration for services rendered to Doulton & Co Limited, in connection with the take-over by its subsidiary which is admitted to be income, and except in so far as it took the place of commissions on sales of goods ordered before, but invoiced after December 31, 1955, the payment in question was not income from the appellant’s business, but was referable to the appellant’s claim for loss of what it and Doulton Co Limited as well considered to be the appellant’s interest in the goodwill and business in Doulton products in Canada. ...

I agree with counsel for the respondent that this agreement must be considered in conjunction with the agreement of the same date, between the appellant and Federated Petroleums Limited (hereinafter referred to as "Federated"), which was executed immediately following the execution of the first-mentioned agreement. ...

Russell’s evidence must be considered in light of a certain bias because he is personally involved in this program. ...