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Bernstein and Kamichik could hardly be considered as the payment of a dividend. ...

., 88 DTC 6025, [1988] 1 CTC 12 (FCTD)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) Since "each taxation year must be considered independently... it is difficult, if not impossible, to conceive how a reassessment for one taxation year can be taken to be superseded by a reassessment in respect of another taxation year. ...

The Queen, 83 DTC 5451, [1983] CTC 432 (FCTD)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits It was stated in the context of the Excise Tax Act that the addition of radios by a Canadian distributor to imported motor vehicles "would not, in normal commercial usage, be considered either as an act of manufacture or production". ...

., 80 DTC 6207, [1980] CTC 216 (FCTD)-- summary under Paragraph 256(1)(b) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(b) It was stated, obiter, that where the Court has to decide whether two corporations are associated by reason of being controlled by the same persons or same group of persons, who might be complete strangers and not persons all related by blood, it is de facto control that must be considered, i.e., whether control of the two corporations is in fact exercised by the same group. ...

Addy, J. stated: "Where the development of the basic food product still involves the growing process and natural biological changes as opposed to artificially manufactured foods or mere processing, I do not feel that, generally speaking, the activity would be considered by the general public anything other than agricultural in nature". ...

Joyal J. noted (p. 5326) that "not all sums paid to a person who happens to be a director of a company will automatically be considered income from that office". ...

What the purchaser says on this point must always be considered, but it may not be decisive. ...

The Queen, 87 DTC 5277, [1987] 2CTC 23 (FCTD)-- summary under Subparagraph 8(1)(i)(iv) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(i)- Subparagraph 8(1)(i)(iv) Dues in order to be considered annual must be of a recurring kind, as opposed to initiation or entrance dues paid once and for all on becoming a member. ...

The Queen, 84 DTC 6087, [1984] CTC 141 (FCTD), aff'd 86 DTC 6164, [1986] 1 CTC 388 (FCA)-- summary under Paragraph 253(b) Summary Under Tax Topics- Income Tax Act- Section 253- Paragraph 253(b) Under the law of Colorado, which was the proper law of the contracts between the American plaintiff and a Canadian finance company, the Canadian finance company could not be considered the agent of the plaintiff with regard to creditor's group insurance policies which the Canadian company was issuing instead on its own account. ...

The fact that (as happened twice in the course of 22 years) the directors might, if they considered that business conditions so demanded, reduce or cancel the amount that had been set up, was not a contingency which negated the fact that the amount set up in the company's books constituted an existing liability. ...