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Canada Forgings Limited treated the amount as a current business expense in its 1976 taxation year since it considered it as a benefit or compensation paid to key employees. ...

Massel, Director, Accounting and Collections Division of Revenue Canada, Taxation. [17]         The relevant part of the Authorization reads: Executive Pool Vehicles The issues raised during our two meetings as well as the comments included in your submission have been considered with regard to the proposed legislation and its effect upon the administration of your executive pool. ...

Nor is this a defalcation case of the type described in Parkland Operations, supra; Cassidy's Limited, supra; Agnew, supra; and IT-185R, where a business is defrauded by an employee or a third party, and the issue becomes whether the resulting loss is reasonably incidental to the income-earning activities.   28        A fraudulent scheme from beginning to end or a sting operation, if that be the case, cannot give rise to a source of income from the victim's point of view and hence cannot be considered as a business under any definition. …   32        In this case, the relevant evidence was tendered by the appellant himself, and the Tax Court Judge concluded from this evidence that he had been the subject of a fraud from beginning to end, a conclusion which precludes the existence of a business. …   [21]          It seems to me that as a result of the decision of the Federal Court of Appeal in Hammill, an activity that is a fraud cannot, in and of itself, constitute a source of income for the purposes of the Income Tax Act (the “ Act ”). ...

For this reason, these two terms should not be read together, and the noscitur a sociis rule does not apply. [50]         Here, the use of the word “or” between “household” and “personal” in the term “household or personal service” supports the view that Parliament intended to distinguish between household services and personal services and intended to include services beyond those ordinarily considered household services. [51]         The fact that the exemption for homemaker services falls within Part II of Schedule V, which deals with health care services, is further contextual support for the conclusion that assistance provided to elderly or infirm persons with the activities of daily living would be included in the concept of “personal service.” ...

Secondly, even if it can be considered that part of Atuhk's place of business was situated on a reserve, few components show the permanence and significance of that place of business. ...

Consequently, the Appellant’s understanding and interpretation, which is reasonably supported by the factual matrix and law, ought to have been known to and considered by the Respondent when accepting the Appellant’s settlement offer. ...

To the extent, the calculation of the reserve considered obligations such as these, the amount of the reserve should be reduced. ...

Since intercorporate dividends are tax free, the appellant considered the result to be a "wash" for income tax purposes with respect to the dividends received, and no extra amount was included in the appellant’s income with respect to these dividends. ...

If the customer paid for that amount up front by purchasing additional kilometres, GMAC considered it to be on income account. ...

Analysis Issue 1: Disposition of debts pursuant to subsection 50(1) [20]         According to paragraph 50(1)(a), a taxpayer (Hill Fai) may elect to be considered as having disposed of a debt that it has established to have become bad in the year. ...