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In particular, subparagraphs 12(1)(x)(ii) through (iv) would bring into income amounts received by a taxpayer from a government that      "... can reasonably be considered to have been received (iii)     as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv)     as a reimbursement, contribution, allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of property or in respect of an outlay or expense". ...

The Court is satisfied that what should be considered here is the use of the space by the Appellant and not the Appellant together with the other co-owners because they had nothing whatsoever to do with the business of the Appellant. (...) ...

MNR, 68 DTC 5180, the court stated: In the absence of any definition in the statute of the expression “capital cost to the taxpayer of property” and in the absence of any authoritative interpretation of those words as used in Section 11(1)(a), insofar as they are being considered with reference to the acquisition of capital assets, I am of opinion that they should be interpreted as including outlays of the taxpayer as a business man that were the direct result of the method he adopted to acquire the assets. ...

" " 20 " "Modification" is considered to be merely a partial alteration of a pre-existing thing. ...

In other words, the subparagraph 75(2)(a)(i) condition would not be considered satisfied from the potential acquisition of the property from the spouse's estate in accordance with the spouse's will. ...

Although the Court in Sedona Networks appears to have implicitly considered that paragraph 251(5)(b) must be applied by simultaneously considering the rights held by all persons, it has not explicitly disregarded CRA's reliance on a selective application of that provision to challenge avoidance schemes intended to circumvent the statutory limitations applicable to the CCPC definition. ...

However, it is clear, I think, that ordinary buildings and an asphalt pavement like the improvements here in question are normally considered to be fixtures. ...

Il a fait les commentaires suivants: «It is my understanding that in those circumstances, that is a part-time personal use of a yacht, the Minister of National Revenue considered that the proper method of evaluating the benefit was by allocating operating costs. ...