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  [41]          Counsel submitted that the parties’ intention regarding the payments made by the shareholders to the Appellant must be considered in the context of all of the agreements relating to the joint venture entered into by all of the parties, including the Trustee.  ...

  [30]          Section 159 provides as follows:   Person acting for another   (1)  For the purposes of this Act, where a person is a legal representative of a taxpayer at any time,   (a)  the legal representative is jointly and severally liable with the taxpayer               (i)   to pay each amount payable under this Act by the taxpayer at or before that time and that remains unpaid, to the extent that the legal representative is at that time in possession or control, in the capacity of legal representative, of property that belongs or belonged to, or that is or was held for the benefit of, the taxpayer or the taxpayer’s estate, and               (ii)  to perform any obligation or duty imposed under this Act on the taxpayer at or before that time and that remains outstanding, to the extent that the obligation or duty can reasonably be considered to relate to the responsibilities of the legal representative acting in that capacity; and   (b)  any action or proceeding in respect of the taxpayer taken under this Act at or after that time by the Minister may be so taken in the name of the legal representative acting in that capacity and, when so taken, has the same effect as if it had been taken directly against the taxpayer and, if the taxpayer no longer exists, as if the taxpayer continued to exist.   ...

.), concerning the former subsection 15(1) of the Act, which the Court considered to be still good law:     In applying paragraph (c) full weight must be given to all the words of the paragraph. ...

Since the expenses are limited to the expenses of the business, it must have been intended that sole proprietors would not be considered to be carrying on a single business simply because the same person is carrying on various diverse activities but the test would be whether the activities are so interlaced and interdependent that the sole proprietor only has one income producing activity ...

“Without any great stretching of interpretation in favour of immediate vesting, may it not be considered that the first words make an immediate gift and that the subsequent limiting words have reference to the time when the legatee shall receive the gift? ...

If he made a single withdrawal from the IRA, Abrahamson was informed by Clarkson, Gordon, the amount of the withdrawal may not be considered by United States tax authorities to be a "periodic pension payment" under section XVIII of the Canada-United States Tax Convention, 1980° [9] and the United States would therefore levy a tax of 30 per cent, instead of 15 per cent, on the withdrawal. is a resident, and (iv) was established principally in connection with, or the principal purpose of which is to administer or provide benefits under, one or more superannuation, pension or retirement funds or plans or any funds or plans established to provide employee benefits; or (d) by a prescribed trust. ...

She also considered that the invoices filed in evidence were not detailed enough. ...

  [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.      ...