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  [74]         While the Appellant has argued that Parliament has filled a gap in section 7, which is a situation where securities are denominated in a currency other than Canadian currency, there is nothing in the statutory language of paragraph 110(1)(d) to suggest that it needs to be considered for any other reason than to determine whether the taxpayer is entitled to the one-half deduction. [75]         The Appellant referred to Canadian Occidental U.S. ...

It is suggested that since the establishment of the office on the reserve was tax-motivated, it was an improper manipulation of the connecting factors test and the office should not be considered a significant connecting factor. ...

This documentary evidence, although customary in mortgage lending would be redundant and absent in single mortgage investments. [52]         On the non-business or investment side, the following facts are to be considered: 1.      ...

The Appellants’ position is that the company should be considered to be situate on the Reserve because its boats are docked as close to the Reserve as is possible (there being no dock available on the Reserve itself), the fishing takes place from a port close to the Reserve, and the company has an office on the Reserve, where it keeps at least some of its corporate records and does some of its business. [35] For the Respondent it is argued that the most important of the connecting factors are the place where the work is done, the nature and purpose of the employment which gives rise to the income, the circumstances surrounding that employment, and the residence of the employees. ...

The respondent's expert witness considered that the fair market value of the shares on that date was $190,000, while the witness for Mrs. ...

In my opinion, when a wife has mortgaged her property to secure the debt of her husband and only her property is at risk, a payment by the husband on his own debt may be regarded as a transfer of property within the meaning of subsection 325(1). [38] I considered a similar situation in Doris White v. ...

Counsel for the respondent explained that he had decided not to call him because he considered the evidence already submitted to be sufficiently persuasive. ...

It is on this point that the trial judge properly considered Beaver’s and Ghitter’s subjective intentions at the time the Purchase Agreement was signed… [18]   [56]   Mr. ...

  [35]          The Federal Court of Appeal considered this decision in OLTCPI Inc. v. ...

[29]     In light of the approach taken by the expert and the comments and observations made by the appellant himself, namely, that he had to grant several months of free rent in order to interest potential tenants, there is reason to believe that the income considered by expert Leblanc was absolutely incorrect since the premises were occupied but did not bring in any revenue because of the owner's free offer. ...