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Canada, [2000] G.S.T.C. 1, the meaning of "substantial" or "substantially all" was considered. ...

  [18]     Counsel for the respondent submits that none of the above should be considered as consideration for the property transfers. ...

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. ...

  [6]     The first issue is whether the Appellant had a source of income to which the expenses in the case at bar are to be considered applicable ...

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. ...

  …   [11]      In drawing the line between “ordinary” negligence or neglect and “gross” negligence a number of factors have to be considered. ...

Surely therefore the transfer must be considered as a form of payment. ...

I have considered the case of Hatherton v. Commissioner for Inland Revenue, [1936] 1 All E.R. 603 that is authority for the proposition that the word "rent" in a taxing statute is not necessarily confined to rent as known at common law. ...

Subsection 227.1(3) has been judicially considered on a number of occasions, but the facts of those cases are so different that they do not really assist in determining the liability of the appellant in this appeal. ...

The transaction in issue had its genesis in December 1986 when the appellant first considered building a residence for himself. ...