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The Appellant relies on Regulation 2900(2)(c):   2900(2)            For the purposes of clauses 37(7)(c)(i)(B) and (ii)(B) of the Act, the following expenditures are directly attributable to the prosecution of scientific research and experimental development:             (a)        the cost of materials consumed in such prosecution;   (b)        where an employee directly undertakes, supervises or supports such prosecution, the portion of the salaries or wages and related benefits paid to or for that employee that can reasonably be considered to related thereto; and   (c)        other expenditures that are directly related to such prosecution and that would not have been incurred if such prosecution had not occurred.   ...

  [24]          Section 6302 of the Income Tax Regulations (“ Regulations ”) states that:   … the following factors are to be considered in determining what constitutes care and upbringing of a qualified dependant:   … les critères suivants servent à déterminer en quoi consistent le soin et l’éducation d’une personne à charge admissible:                      (a) the supervision of the daily activities and needs of the qualified dependant;   a) le fait de surveiller les activités quotidiennes de la personne à charge admissible et de voir à ses besoins quotidiens;   (b) the maintenance of a secure environment in which the qualified dependant resides;   b) le maintien d’un milieu sécuritaire là où elle réside;   (c) the arrangement of, and transportation to, medical care at regular intervals and as required for the qualified dependant;   c) l’obtention de soins médicaux pour elle à intervalles réguliers et en cas de besoin, ainsi que son transport aux endroits où ces soins sont offerts;   (d) the arrangement of, participation in, and transportation to, educational, recreational, athletic or similar activities in respect of the qualified dependant;   d) l’organisation pour elle d’activités éducatives, récréatives, athlétiques ou semblables, sa participation à de telles activités et son transport à cette fin;   (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;   e) le fait de subvenir à ses besoins lorsqu’elle est malade ou a besoin de l’assistance d’une autre personne;   (f) the attendance to the hygienic needs of the qualified dependant on a regular basis;   f) le fait de veiller à son hygiène corporelle de façon régulière;   (g) the provision, generally, of guidance and companionship to the qualified dependant; and   g) de façon générale, le fait d’être présent auprès d’elle et de la guider; (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.   ...

The Queen, 2010 TCC 483, the Court considered that the words of the Act clearly contemplated or required that there be a "new work location" for a taxpayer to qualify for the moving expenses deduction. ...

There are no other allegations of scandal, frivolity, vexatiousness or abuse to an extent that would need be considered in the context of a motion to strike an action.   ...

Their case was very carefully considered and it seemed to my colleagues and myself that it was a fair case they had put forward. ...

However, the offices were not considered entirely suitable for use by the Appellant in their then-existing state. ...

While the existing case law deals with interest income derived from cash investment certificates as opposed to royalty income derived from mineral interests, money cannot be equated with goods and services themselves and therefore it is logical that in order for interest to be considered active business income the underlying cash must be shown to have a close connection with the business. ...

Actually, she did not even have the supporting documents for these costs because the accountant had not considered them to be capitalizable costs. ...

I underscore these two points in that passage: (i) the deemed benefit under paragraph 7(1)(a) was in fact included in computing the plaintiff's cost of the option shares pursuant to section 9 of the Act; and (ii) McNair, J. considered that it was both fair and proper for the Minister to determine the plaintiffs business profits in respect of the shares in that way. [5] The appeal is allowed and the matter is referred back to the respondent for reconsideration and reassessment on the basis that what happened regarded the 5,000 shares renders the matter an adventure or concern in the nature of trade. ...

As clarified in written submissions received from the respondent following the hearing, these amounts do not have to be considered separately because they are part of the child tax benefit in section 122.61 of the Act.   ...