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This, as we know, is an irrebuttable presumption and all transfers of property between husband and wife are considered to be "not at arm's length". ...

(l.2)       for reasonable expenses relating to renovations or alterations to a dwelling of the patient who lacks normal physical development or has a severe and prolonged mobility impairment, to enable the patient to gain access to, or to be mobile or functional within, the dwelling; (l.21)     for reasonable expenses, relating to the construction of the principal place of residence of the patient who lacks normal physical development or has a severe and prolonged mobility impairment, that can reasonably be considered to be incremental costs incurred to enable the patient to gain access to, or to be mobile or functional within, the patient's principal place of residence. [4]      Paragraph 118.4(1)(a) reads: 118.4(1)            For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a)         an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months. [5]      The Crown does not dispute that the amounts were spent. ...

In 1998, the Minister accepted the Appellant's expenses of $3,125 paid by him to move from Calgary to Mississauga and not reimbursed by his employer. [4]            The Appellant submits that his move was from Calgary to Campbellville with an interim stay in Mississauga to be considered as a hotel or stopover before finding their permanent home. ...

.), which he had not considered in Peel. In Savage, the Supreme Court of Canada held that a monetary award paid to the taxpayer by an employer for passing employment related courses was taxable under paragraph 6(1)(a) and stated that the words “in respect of” were words of the widest possible scope. 9 With respect, I think that Judge Taylor was right in Peel. ...

To the extent I am either not fully understanding CRA's policy or not fully agreeing with it, I have already concluded that, as a matter of law, the two representative agreements in this appeal are providing the Appellant simply with the right to access information via the website for a fee, so the CRA bandwidth policy would not apply in any event. [12]         On that basis, I cannot conclude that, in law, they could be considered payments to the vendors for the lease of equipment. ...

., [1990] 1 C.T.C. 2432; 90 D.T.C. 1330, in which a subject similar to the instant matter was considered. ...

  [6]      In my view a bad debt cannot be considered to have been written off in a person’s books of account unless and until a notation is made in those books that the particular debt has been written off. ...

With all due respect, the presumption that the legislator did not by his legislation intend to require anyone to do the impossible was not considered and then rejected, and as this is an aspect which in my opinion is important in determining the subject appeal, I do not feel bound by the decision in Steer. ...

This means that the property falls within the concluding portion of subsection 123(1) and, therefore, it must be excluded from the definition of residential complex and considered a taxable supply made in the course of a commercial activity ...

Nothing in the reasons for judgment in that case indicate that the Court considered or decided either the question whether a company which had been dissolved had the capacity to conduct litigation or whether a former director had the right to conduct litigation on behalf of a dissolved corporation. ...