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Advances to a shareholder should be considered as loans only at the end of the financial year of the corporation. It is then that amounts owing by a shareholder might be considered as forming “ part of a series of loans or other transactions and repayments". ...

Recognition of an unlisted institution as a university will be considered at the request of the institution. ... The same paragraph of the bulletin seems to state as well that recognition of an unlisted institution will be considered at the request of the institution. ...

  [17]         The respondent submits that the sum of $1,050,000 was not paid to 4178092 by the appellants and that, even if that had been the case, the payment of said amount was not made by the appellants for the purpose of effecting a disposition of the shares and should therefore not be considered for the purposes of calculating the capital gain in accordance with paragraph 40(1)(a) of the Act.   ...   [30]         For the purposes of determining the proper value to be accorded to the non‑competition clause, the appraiser considered the following factors on which he had information:             (a)   state of the market and the state of the competition;           (b)   barriers to entry in relation to the shareholders’ options to compete;           (c)   clients’ mobility;           (d)   labour mobility;           (e)   shareholders’ financial ability to compete;           (f)    the shareholders’ age (54, 56 and 68 years old in 2003); and           (g)   the shareholders’ experience.   ...

This last factor is considered key in the determination.   Nature of property sold   [24]     The Hamburg property was partly residential and partly commercial real estate. ... It must be considered that Mr. Zaenker had a long history of buying and selling property; he was a real estate broker; he was very successful at reselling properties at a profit; he often mortgaged properties to the maximum extent possible. ...

Article 237.1- Definitions- In this section: "tax shelter" means any property in respect of which it may reasonably be considered having regard to statements or representations made or proposed to be made in connection with the property that, if a person were to acquire an interest in the property, at the end of any particular taxation year ending within 4 years after the day on which the interest is acquired, (a)         the aggregate of all amounts each of which is: (i)          a loss represented to be deductible in computing income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year or any preceding taxation year, or (ii)                 any other amount represented to be deductible in computing income or taxable income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year, other than any amount included in computing a loss described in subparagraph (i),                    would exceed (b)                the amount, if any, by which                                                    (i)                   the cost to the person of the interest in the property at the end of the particular year,                                                  (ii)                   would exceed the aggregate of all amounts each of which is the amount of any prescribed benefit that is expected to be received or enjoyed directly or indirectly in respect of the interest in the property, by the person or a person with whom the person does not deal at arm's length but does not include property that is a flow-through share or a prescribed property. [6]      A second issue was raised at the hearing, i.e. whether the assessment was issued within the time prescribed by the Act. ... The opinion expressed in Exhibit I-3 warns the reader that it is possible that the tax authorities consider that the purchase of interests constitutes a conferred benefit that reduces the cost of investing and, that being the case, the proportion of the research and development expense in the partnership for the partner is higher than the cost of investing reduced by the proceeds from the disposition of the shares and that the project would be considered a tax shelter and that a number would have to be obtained. ...

  [21]          The respondent claims that the subject of the donations must be considered to be a single PUP because the appellant and Université Laval chose to define the donations as a [Translation] “collection of insects” on the charitable donation receipt issued to the appellant. ... The donated insects are thus considered to be distinct properties and are treated as such. ...

Poulin had “knowingly" participated in the filing of a tax return which on the surface he should have known might have included the amounts at issue, if he considered them income. ... I would just note for the record that the assertion of counsel that the amount for 1977 he considered for assessment under subsection 15(2) of the Act, rather than under subsection 15(1) of the Act are rejected for essentially the same reasons as those provided herein for the years 1976 and 1979. ...

  [30]     I have also considered whether, regardless of TELUS’ intent, the actual business use of the vehicle by Mr. ... Alloway admitted he considered the parking pass had enabled him to work overtime and to receive better raises and achieve promotion within Telus. ...

  (17.2)               For the purposes of subsections (1.11) and (17), gross revenue derived in a taxation year from (a)        the right of a person or partnership, other than the owner of a property, to use or occupy the property or a part thereof, and (b)        services offered to a person or partnership that are ancillary to the use or occupation by the person or partnership of the property or the part thereof shall be considered to be rent derived in the year from the property ... Revenue derived from the right of a person or partnership (except the owner) to use or occupy the property, and revenue from services offered that are ancillary to such use or occupation, are considered to be rent. ...

Neither the acknowledgment of debt nor the accounting changes could alter that fact. 3.03.4 In those cases, the points at issue were whether or not a bona fide receivable (1), a promise to repay $50,000 (2), the granting of a mortgage (3), a debt due by the company to the appellant, etc. can be considered as the repayment of the loan made by a company to the taxpayer. ... In my opinion, the letter issued by the appellant's father in November 1984 cannot be considered as having a retroactive effect in the present circumstances. 3.03.8 Concerning the fact that the respondent allowed the notice of objection for the taxation year 1981 and not for 1982, it is the Court's opinion that if it were part of the instant case, that appeal for 1981 would also have been dismissed. ...