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The following criteria should be considered: the profit and loss experience in the 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. ... This situation might well be one of the few in which a legitimate claim for "start-up costs" should have been considered. ...

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 snow a profit after charging capital cost allowance. ... The evidence does not support the claim of the appellant that the losses in question should be considered start-up costs. ...

However, legal costs incurred in obtaining a court order described in 16(b) above, are considered to be deductible in computing the individual's income where the individual must sue the spouse ora person described in subparagraph 56(1)(c.1)(iii) for maintenance in a Family Court or under legislation such as the Family Services Act of New Brunswick, Part III of the Family Law Act of Ontario or other similar legislation. The latter types of expenses are considered to relate to the enforcement of a preexisting right provided by law, and not to the creation of a new right; see the decision of The Queen v. ...

The schedules annexed to the Minister's replies show that the milk quota was considered to be eligible capital property and that Ben Van Miltenburg’s father had claimed a capital gains deduction pursuant to section 110.6. ... That being so, the Minister is required, pursuant to subsection 14(3), to deduct amounts which may" reasonably be considered to have been claimed” by the vendor as a deduction under section 110.6. ...

Subsection 60.1(3) reads as follows: For the purposes of this section and section 60, where a decree, order or judgment of a competent tribunal or a written agreement made at any time in a taxation year provides that an amount paid before that time and in the year or the immediately preceding taxation year is to be considered as having been paid and received pursuant thereto, the following rules apply: (a) the amount shall be deemed to have been paid pursuant thereto; and (b) the person who made the payment shall be deemed to have been separated pursuant to a divorce, judicial separation or written separation agreement from his spouse or former spouse at the time the payment was made and throughout the remainder of the year. ... Appeals dismissed. 1 I have not considered whether the appellant would have been successful in his submission had the agreement been filed with any of these courts. 2 See Black’s Law Dictionary, 4th ed. 1968, page 1401, and The Concise Oxford Dictionary, 6th ed. 1976, page 903. ...

It is a remedial section and it reads as follows: (3) For the purposes of this section and section 60, where a decree, order or judgment of a competent tribunal or a written agreement made at any time ina taxation year provides that an amount paid before that time and in the year or the immediately preceding taxation year is to be considered as having been paid and received pursuant thereto, the following rules apply: (a) the amount shall be deemed to have been paid pursuant thereto; and (b) the person who made the payment shall be deemed to have been separated pursuant to a divorce, judicial separation or written separation agreement from his spouse or former spouse at the time the payment was made and throughout the remainder of the year. ... Where an order or a written agreement seeks to make subsection 60.1(3) applicable, it should specify the amounts paid in the taxation year or an immediately preceding taxation year and it should provide that such amounts are to be considered as having been paid and received pursuant to the order or written agreement (Stewart v. ...

Students were generally considered unsuitable and unreliable. They wanted a couple with steady jobs who would take care of the property. ... It remained a source of income and an investment property until they moved into it on November 1, 1989, While they may have considered the alternative of using it for their own residence, the application of the Income Tax Act is not based upon the vagaries of a taxpayer's consideration of alternative uses. ...

(e) The Farmers' Income Tax Guide for 1982 published by Revenue Canada commented: Where the aggregate amount of the business investment tax credits deducted in the calculation of "Average Tax", for 1978, 1979, 1980, 1981 and 1982 is greater than the aggregate of similar credits used to reduce the federal tax otherwise payable for 1978, 1979, 1980 and 1981, you will be considered to have deduction the lesser amount in respect of those years. ... In this case you will be considered to have deducted total business investment tax credits of $5,600 in 1980-1982 and no adjustment to the capital cost of qualified property will be required. ...

In regards to the other out of Canada trips, they are different in nature and should be considered as convention expenses under section 20. ... Where a business has not been able to generate a profit, or at least show a reasonable expectation of profit in the near future, section 67 should seriously be considered. ...

Tait would have considered such as income. This decision was subsequently confirmed by the Supreme Court of Canada in Re Lauer and Stekl (1975), 54 D.L.R. (3d) 159. ... In no way can an asset on hand which is normally considered as income become a capital asset of a spousal trust nor can it remain as an income asset and not be the property of the life tenant. ...