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The CRA considered the objections and confirmed the assessments after Mr. ...

His drawings, so to speak, from the corporation, which he considered as advances against earnings, were made on an irregular basis, the cash flow of the corporation at any given point in time being a factor. ...

The letter also noted that no remittance of the penalty “appears to have been made" with the designation forwarded on October 17 and “ consequently, the designation in question cannot be considered to be filed as a valid designation in accordance with subsection 194(7) as the applicable penalty of $8,000 has not been remitted”. ...

It was specifically and repeatedly confirmed in paragraph 6 of the Amending Agreement that, "In the event any provision of the Original Partnership Agreement as amended by this Agreement should have the effect of imposing upon any Limited partner any of the obligations of the General Partner, such provision shall be of no force and effect and shall not be considered a part of the Original partnership Agreement as amended by this Agreement, by the remainder of the Original Partnership Agreement as amended by this Agreement shall continue in effect. ...

The Parties considered, in the alternative, the application of paragraph 8(1) (f), but for the reasons that follow it will be unnecessary for me to address that provision. ...

., [1984] C.T.C. 387, 84 D.T.C. 6374 (F.C.T.D.) at 405 (D.T.C. 6389): It is a rule of construction that, where in the same Act, and in relation to the same subject matter, different words are used such choice of different words must be considered intentional and indicative of a change in meaning or a different meaning. ...

This would indicate that the Court felt that all factors should be considered as a group and no one factor should determine the existence of a source of income. ...

The entire investment picture should be considered (Smith). 12.            ...

If resort to extrinsic material of this kind, or to the legislative history, were considered useful, then the most helpful material would be the amendments made to section 1400 in 1990 and 1996. ...

The Queen [5], the Supreme Court of Canada considered the distinction between income from a business and income from property. ...