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Automobile Association, [1974] 1 WLR 1447 (HL)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Upon paying for membership in the Automobile Association, a member was considered to be paying not for the mere privilege of membership but for the benefits that a member received under his contract with the Automobile Association and, accordingly, the subscription price is apportionable among those services and facilities received by each member. ...

.)-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) demand note not bona fide repayment arrangement Te defendant was found to be negligent in not advising of the risk that the signing by the individual plaintiff of a demand promissory note as security for a housing loan made to her would not be considered to represent a bona fide arrangement for repayment of the loan within a reasonable time. ...

The Queen, 2004 DTC 2232 (TCC)-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 Bonuses paid to children of the taxpayer's controlling shareholders that clearly were unreasonable in amount in relation to the services rendered by them were not deductible notwithstanding a position of the taxpayer (that was not accepted by Lamarre Proulx T.C.J.) that the bonuses should be attributed to the parent managers pursuant to s. 56(2) and, as a result, considered reasonable in relation to the services rendered by such managers. ...

Profit- Patents and Know-How The taxpayer, which was formed for the purpose of acquiring and exploiting patents and licences and which licensed its patent rights to foreign manufacturers, typically with an option on their part to purchase, realized a taxable profit when such an option was exercised, given that such a dealing in patents should be considered to be part of its business. ...

Further, it could be seen that the issue of undue delay was considered in the decision not to waive interest and penalties as the decision referred to the complexity of legal issues involved. ...

Willann Investments Ltd. (1989), 63 DLR (4th) 760 (Ont CA)-- summary under Subsection 248(7) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(7) An offer was considered to have been "delivered" to a person ("Willann") when it was faxed to Willann: "Where technological advances had been made which facilitates communications and expedite the transmission of documents we see no reason why they should not be utilized. ...

Bell T.C.J. found that having considered and allowed the initial request for a loss carry back, the Minister was foreclosed from further reassessing the 1987 taxation year. ...

Kerr, J. held that in order for the taxpayer to be considered to have "incurred" an expense in the year it must have obligated itself in the year to pay the bonuses. ...

The matter was referred back to the CBSA for reconsideration in light of s. 144.01, because the CBSA had not considered this provision in its determination to assess GST with respect to the natural gas coming into Ontario. ...

In also rejecting Elfe’s submission that the Court should simply annul the interest itself, he noted that the ARQ had not even considered whether it was appropriate in the particular circumstances to annul interest below the 4% level, and had not been informed of the MNP advice, and stated (at para. 40): Given the breadth of issues that could be considered by the Agency and its jurisdiction in this matter, the Court will not exercise the discretionary power of the Agency. ...