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Also, the respondent submits that the order of Justice Morse should be considered the same as a garnishee. ... The effect of the “without prejudice” portion of the discharge from bankruptcy (see fact No. 3) was that the assets in question were to be considered as assets available to the creditors if the actions were successful. ...

Justice Robertson considered the specific question at page 376 (D.T.C. 6539) when he asked the rhetorical question whether the impugned legislative provision is discriminatory in its effects. ... It does cut the Gordian knot by creating distinctions between dependent and non- dependent children, the former being included in the family unit and receiving their refundable tax credit through that channel, the latter being considered, as any other unattached individual, a tax unit on its own and receiving the tax credit personally. ...

The Minister of National Revenue (Minister) considered this sum as a taxable benefit and Mr. ... To sum up, when all the circumstances surrounding Tele-Direct’s payment of compensation are considered, one realizes that it was a sum determined in advance which did not vary on the basis of disbursements or of the loss which Mr. ...

The Federal Court of Appeal then considered full farming losses in the case of Poirier Estate v. ... A person who chooses to begin farming as a second or third career after having been successful at previous endeavours, and therefore able to enjoy a steady income, would not become disentitled from being considered a class 1 farmer merely because the quantum of the farming income would be unlikely to ever match that of the pension, investment or other amounts of income generated in a passive sense. ...

It might be argued that it is a mere play on words—but when considered in the light of the jurisprudence going back to Ransom v. ... The learned justices in Phillips, supra, discreetly left intact the basic principles permitting the possibility of some amounts to be considered "non-taxable”. ...

Brian Smith, the general manager of all three companies, the three companies were considered one business entity and intercompany loans were not unusual. ... However, in Cartwright, the Court noted that corporate assets acquired for the purpose of earning income but used incidentally by a shareholder would be considered a benefit to the shareholder equal to the amount he would have been required to pay to obtain the same benefit from a corporation of which he was not a shareholder (see Youngman, supra, at page 15 (D.T.C. 6325). ...

The appellant considered that he really had no other realistic option but to agree with this change in market strategy on the part of Marineland. ... This question was considered by the Federal Court of Appeal in the case E.S.G. ...

While it was unnecessary for the purposes of these appeals that I deal at length with the point, the Crown's position is so out of line with both the law and with prevailing practice and could potentially have such far-reaching effects on any number of appeals before this Court that I considered it desirable that the idea be nipped in the bud. ... This is a matter that will have to be considered by the Minister when he reassesses. ...

If this plan was ever seriously considered it was quickly abandoned. There is clear evidence that, at least as early as November of 1986, plans for demolition of the building at number 3540 had been made. ... He therefore considered that the buildings added nothing to the value of the land in the market place. ...

The respondent points out that much of the travel relates to trips from Renfrew, where Pearl-Anne lived, to Ottawa and back and that a large portion of those trips should be considered as personal driving to and from work as opposed to driving while working. ... In that event the $15,375 would be considered as replacement financing and the interest thereon would normally be deductible. ...