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Ct.), Shepard, D.J. considered whether insurance proceeds, which the taxpayer received for payments under warranties, were income for_tax purposes. ... There is no doubt that had the plaintiff actually earned the income for which the insurance proceeds are replacements, they would have been considered production profits... ... General and Administrative Expenses 24(1) In Johns-Manville Canada Inc. v M.N.R., 85 DTC 5373 (S.C.C.), the court considered whether the taxpayer's cost of acquiring land in the course of asbestos mining was on account of capital or income. ...

Generally, all pulp mills are considered to be initial processing operations in a resource-based industry and thus do not qualify. ... Where a pulp mill produces some pulp for market and the rest is used by the taxpayer for conversion into paperboard or paper other than newspaper, it is necessary to segregate the capital costs of the property relating to the integrated paper operation, which are considered to be part of a "facility", from those costs relating to the market pulp operation which are considered to be part of a "facility". 5) In order for equipment of an oil well service company such as Halliburton Services Ltd. to qualify as "certified property", it would have to be part of a "facility". ... None of the exceptions listed in the definition are considered to apply to oil and gas in situ plants. ...

Similarly, any forfeiture of an employee’s existing salary or wage entitlement in exchange for a travel allowance is not considered to be an amount paid in respect of travel expenses. ... Where an employment contract is of indefinite duration, it is a question of law and fact whether a valid renegotiated employment agreement is in place and if a travel allowance provided for would be considered to be paid in respect of travel expenses for purposes of section 110.7 of the Act. ... Accordingly, the non-unionized employees in the situation you describe would have access to the travel deduction irrespective of whether the travel allowance provided is considered to be paid in respect of travel expenses for purposes of section 110.7 of the Act. ...

(3) If there are multiple businesses being carried on by several different corporations, would this condition be met if an individual is only considered to be actively engaged on a regular, continuous and substantial basis in one of the businesses? ... It is considered to be one of the hallmarks indicative of a genuine intergenerational business transfer. ... Accordingly, any previous engagement or involvement by an individual prior to the disposition of the subject shares by the parent to the purchaser corporation would not be considered in determining whether the condition in proposed subparagraph 84.1(2.31)(f)(ii) or 84.1(2.32)(g)(ii), as the case may be, is met. ...

To the extent a government is not making an ordinary commercial investment in respect of contributions that it makes to a taxpayer, the government would generally be considered to be providing the taxpayer with government assistance. ... Where a personal or hobby element to the taxpayer’s activity exists, the activity will be considered a source of income from business or property only if the activity is undertaken in a sufficiently commercial manner. ... In the context of the situation described, if a homeowner intends to rent their XXXXXXXXXX Suite for a profit, their activity will likely be considered a source of income from business or property for purposes of the Act and as such, the Grant will be considered income from that particular source. ...

In addition, you stated that you understood that, in the context of a payment for a service, CEDOE does not generally include the costs incurred to perform that service and you enquired whether certain non-insurable risks and liabilities (e.g., losses from crashing) could be considered to be “costs incurred” for this purpose. ... As a result, an amount paid for XXXXXXXXXX services performed by ACO for BCO would be considered CEDOE to the extent the amount exceeds the costs incurred by ACO to provide the service. ... In addition, the Courts have held that a taxpayer will not be considered to have incurred an expense unless and until the taxpayer has an absolute and unconditional legal obligation to pay an amount. ...