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Section 144.01 also ensures that the commodity is still considered “in-transit” when it is stored or taken up as surplus product for a period until it is further transported. ...

The key part of the reasoning in that case is found in paragraph 11, which reads as follows: [...] where investment income is at issue, it must be viewed in relation to its connection to the Reserve, its benefit to the traditional Native way of life, the potential danger to the erosion of Native property and the extent to which it may be considered as being derived from economic mainstream activity. ...

A worker is entitled, for the first five working days of his work stoppage, to be remunerated at his regular wage rate and to also receive from his employer, where section 42.11 or 1019.4 of the Taxation Act (chapter I-3) applies to the worker, remuneration equal to the aggregate of the tips that could reasonably be considered to be attributable to those days and that the worker would have reported to his employer under that section 1019.4 or that his employer would have attributed to him under that section 42.11. ...

In her opinion, payments made to third parties cannot be considered to be amounts payable as an allowance to the recipient and therefore deductible by the payer, unless the subsection numbers are expressly stated in the written agreement. ...

Those submissions were received and reviewed. [36]            The power of this Court, on an appeal from the Tax Court, is to dismiss the appeal or give the decision that should have been given, or to refer the matter back to the Tax Court for determination in accordance with such directions as are considered appropriate (paragraph 52(c) of the Federal Court Act, R.S.C. 1985, c. ...

From paragraph 137 to paragraph 145, and at paragraph 248 of its reasons, the Federal Court carefully considered the characterization issue, concluding that: 139 ...

If the context is properly considered, the Crown suggests, it is clear that the Terminal should not qualify for CCA at the rate of 30 percent. ...

This issue was considered by the Court of Appeal (Civil Division) in Locabail (U.K.) ...

In both cases, the Federal Court applied subsection 116(1) to calculate the rate of interest that could be claimed by the SOPF. [53]            Having duly considered all of the above, I conclude that the claims against an owner of a ship or its guarantor referred to in subsection 116(1) are claims by the SOPF against the said shipowner or its guarantor. ...

The transactions that have been completed would have been disclosed in filings and documents available to the Minister and therefore, the transactions themselves would no longer be considered confidential vis-a-vis the Minister. [6]   In paragraph 3 of their memorandum of fact and law, Abacus and Gillis indicate that the “Memo” which is the subject of this appeal, is the memorandum in which the lawyers opine “on how to buy the shares in the most tax-efficient manner”. ...