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.), Rouleau, J. discussed whether an interest free loan or low interest loan may be considered a benefit and thus taxable under one of several provisions of the Act: sections 6, 15 and 105. ...

In such circumstances the purchasers' rescission rights to which the limited partners are entitled are specified in paragraphs 3 and 4 of that portion of the offering memorandum which reads: 3(1) A person or company that is a party to a contract as purchaser resulting from the offer of a unit has a right to rescind the contract while still the owner of the unit if the offering memorandum received by the purchaser, as of the date of receipt, contains an untrue statement of a material fact or omits to state a material fact necessary in order to make any statement contained therein not misleading in the light of the circumstances in which it was made. (2) No action shall be commenced under this paragraph after the expiration of 90 days from the last to occur of the receipt of the offering memorandum by the purchaser or the date of the contract referred to in subparagraph (1). (3) Subparagraph (1) does not apply to an untrue statement of a material fact or an Omission to state a material fact; (a) if the untruth of the statement or the fact of the omission was unknown to the vendor and, in the exercise of reasonable diligence, could not have been known to the vendor; (b) if the statement or omission is disclosed in an amended offering memorandum filed with the Superintendent of Brokers as soon as practicable and in any event within 10 days from the date the change occurs, and the amended offering memorandum was received by the purchaser; or (c) if the purchaser knew of the untruth of the statement or knew of the omission at the time he purchased the security. (4) The cause of action conferred by this paragraph is in addition to and without derogation from any other right the purchaser may have at law. 4(1) For the purpose of paragraphs 1 and 3 where the offering memorandum (which term in this paragraph includes an amended offering memorandum filed with the Superintendent) is sent by prepaid mail, the offering memorandum shall be deemed conclusively to be received in the ordinary course of mail by the person or company to whom it was addressed. (2) The receipt of an offering memorandum by a person or company who is acting as agent of or who thereafter commences to act as agent of the purchaser with respect to the purchase of a unit is, for the purpose of paragraphs 1 and 2, receipt by the purchaser as of the date on which the agent received the offering memorandum. (3) For the purpose of paragraphs 1 and 2, a person or company shall not be considered to be acting as agent of the purchaser unless the person or company is acting solely as the agent of the purchaser with respect to the purchase and sale in question and has not received and has no agreement to receive compensation from or on behalf of the vendor with respect to the purchase and sale. ...

The financial schedule reproduced above is illuminative of the whole situation and is to be considered as a part of the determinative factors to be employed. ...

He considered the financial projections, the problems with the bank, and viewed it as a long-term investment, much the same as those of the Jecco Group. ...

., [1988] 2 C.T.C. 2180; 88 D.T.C. 1531, this Court considered a situation in which the appellant in that case had resigned as a director but the resignation become irrelevant when it was decided that Mr. ...

Provision of the suite in question is considered by the Minister on behalf of Her Majesty to be part of the remuneration for their services. ...

Appeal dismissed. 1 ''Commonwealth Construction was considered and applied in Foothills Pipe Lines (Yukon) Ltd. v. ...

Additionally, the Act in subsection 248(3) specifically provides for the exclusion of those classes of interests which under ordinary circumstances might be considered an interest in real property, such as by way of mortgage or reservations under an agreement for sale. ...

The speed with which the business went bad and the appellant's state of nervous exhaustion brought on by his family and business situation have to be considered. ...

Harrowsmith had not been for sale at the time and the principals of the appellant believed the offer was far in excess of what they considered the value of the company to be. ...