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The Tax Court judge agreed with the Crown that the criteria set out in this provision for claiming a deduction must be considered separately (Reasons, paras. 21-22). [18]   He first sought to determine whether a gift had been made. ...

Counsel for the appellants acknowledged that the use of the condominium may be considered to have an element of personal use and benefit. ...

I think it’s quite clear and if this is not a sufficient admission for my friend, we can talk about it some more, but up to and including the careful review of this proposal by Verchere, when he suggested a two-step approach to the 51/49, nobody considered anything other than 51/49, neither Mr. ...

In either case the Court considered the language of the statute to apply. ...

It might perhaps be said that it met the "busi ness" test and the "reasonable expectation of profit” test if only Canadian operations are considered. ...

At first glance, the difference between the two values should be considered as capital gain taxable in the year it was received, in 1982. ...

I have considered the Minister’s request and the factors set out in Rule 400(3) in light of the mixed result in this application and will award costs to the Minister in the amount of $1,250.00.   ...

This is said at page 18 under the heading “Deferred Foreign Exchange Gain”: This suggests that if the debentures could be considered as capital debt obligations, the gain when realized at maturity should be reported on account of capital. ...

Faucher felt ill at ease with this arrangement, which he considered presented him with ethical problems. ...

Timeliness [46] As indicated in Continental Bank Leasing, one of the factors to be considered by the Court, when determining whether a proposed amendment would serve the interests of justice, is the timeliness of the motion to amend. [33] Given that the Respondent had included paragraph 51 in her Reply in Chad II, which was filed on May 27, 2019, the current Motion to amend (so as to add proposed paragraph 39.1 and other provisions), notice of which was filed June 29, 2021, was anything but timely. ...