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Capital gain on disposition of corporation shares for $2,250, $1,687 of which is taxable, calculated as follows: Proceeds of disposition $15,000 Less: Deemed dividend 12,000 Net proceeds of disposition 3,000 Less: Adjusted cost base 750 Capital gain $ 2,250 Taxable at 75% $ 1,687 d. considered tax credit for dividend of $ 1,999.99 Mr. ...

Appeal allowed. 1 An inordinate amount of time is considered to be a time so great that your patient would not perform the activity if it was not necessary. 2 [1996] 3 C.T.C. 2510. ...

Those years will have to be considered on their own. The appeal for 1994 is dismissed. ...

A capital gain is an element that is taken into account in computing the child tax benefit since it is included in computing an individual’s income; an individual’s income is one of the elements considered in the application of subsection 122.61(1) of the Act. ...

Analysis and Decision Three recent decisions of the Federal Court of Appeal, namely Tonn, 96 DTC 6001; Mastri, 97 DTC 5420 and Mohammad, 97 DTC 5503 have ana- lyzed and distilled the factors to be considered in determining whether a taxpayer can be said to have a reasonable expectation of profit from a rental operation. ...

In her testimony Muguette Nadeau, an appeals officer, maintained that she took her decision in accordance with the factors laid down in s. 6302 of the Income Tax Regulations (“the Regulations”), which read as follows: 6302 For the purposes of paragraph (h) of the definition “eligible individual” in section 122.6 of the Act, the following factors are to be considered in determining what constitutes care and upbringing of a qualified dependant: (a) the supervision of the daily activities and needs of the qualified dependant; (b) the maintenance of a secure environment in which the qualified dependant resides; (c) the arrangement of, and transportation to, medical care at regular intervals and as required for the qualified dependant; (d) the arrangement of, participation in, and transportation to, educational, recreational, athletic or similar activities in respect of the qualified dependant; (e) the attendance to the needs of the qualified dependant when the qualified dependant is ill or otherwise in need of the attendance of another person; (f) the attendance to the hygienic needs of the qualified dependant on a regular basis; (g) the provision, generally, of guidance and companionship to the qualified dependant; and (h) the existence of a court order in respect of the qualified dependant that is valid in the jurisdiction in which the qualified dependant resides. ...

Paragraph 56(1)(v) of the Act reads as follows: 56: Amounts to be included in income for year — (1) Without restricting the generality of section 3, there shall be included in computing the income of a taxpayer for a taxation year, (v) Worker’s compensation — compensation received under an employees’ or workers’ compensation law of Canada or a province in respect of an injury, a disability or death; (emphasis added) The concept of the receipt of an amount and the relevant taxation year has already been considered by the courts; I am referring, inter alia, to Vegso v. ...

The term “renovate” was considered judicially in Edinburgh Parish Council v. ...

In this context, I note that $.3472 per kilometre is considered to be a reasonable expense incurred by such person when required to use his vehicle for government business. ...

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. ...