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Even though reserves carried over from 1987 transactions are not expressly mentioned in subsection 110.6(2.1), Parliament was aware at the time the legislation was passed that the Department of Finance considered the enhanced deduction to apply to 1987 transactions occurring after 17 June 1987 only in respect of reserves carried over into subsequent years. ...

Through the years, of course, courts have attempted to express certain principles which should be considered whenever the perennial question came up. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

In a similar vein, Mr Justice Dickson lists, again at 314 [5215], a number of criteria which might be considered in the determination of a “reasonable expectation of profit”, such as “... the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance.” ...

The amount had to be considered as an outlay for gaining income from an adventure in the nature of trade and not as an outlay or loss on account of capital. ...

The CCRA then considered whether it was appropriate in the circumstances to exercise its discretion to cancel or reduce the penalty and interest charges under the "fairness legislation" of the Income Tax Act, R.S.C. 1985 (5th Supp.), c. 1 (the "Act"). ...

As well OMC had recently indicated that its relationship with the plaintiff would continue indefinitely because, according to Bell, OMC personnel had told him that the plaintiff company was doing the job in Newfoundland better than the management at OMC considered it could do it. ...

Essentially, his evidence was to the effect that the $500,000 payment was not made to purchase a business but only to expeditiously cancel a distributorship arrangement that had been considered for some time to be less than satisfactory and that the payment was made as a matter of fairness and common decency to cushion All World against the impact of the takeover and to ensure the continuance of good business relations. ...

Weinstein said that basically they considered the partnership and limited company as one group. ...

Dulk considered this to be evidence that no Notice of Objection was received by the Minister within the time limit stipulated in subsection 165(1) of the Act. ...