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The trial judge, of course, considered the nature and effect of Mr Cival's arrangement with the Department. ...

The Queen, [2] Woods J. considered documentary evidence over viva voce evidence in deciding the character of a settled amount. ...

The Appellant and his son Samuel considered expanding the lending activity by contacting two other lawyers believed to be sources of potential mortgage loans. ...

  [24]         In the case at bar, there was no conspiracy to prejudice the tax authorities, a fact which, as the Federal Court of Appeal noted in Livingston, supra, could be considered crucial. ...

To rectify the problem the board of directors considered restructuring the company. ...

.), at para. 50:... the answer to that question requires the application of a judge-made rule, sometimes called the " surrogatum principle", by which the tax treatment of a payment of damages or a settlement payment is considered to be the same as the tax treatment of whatever the payment is intended to replace. ...

The proper approach must be a functional one, and the scheme must be considered as a whole, taking into account the intent of the legislation, its object and spirit and what it actually accomplishes. 28 I need not recite the numerous interpretive principles that have been developed over the years. ...

International Tax Services paid the taxpayer a sum, which he considered to be a retiring allowance. ...

As to the alternative submission (which Lord Thankerton stated was not seriously pressed), it seems clear that the amount remitted was properly considered as a capital item. ...

Under no circumstances shall any benefits accrue to any body corporate. 29.2      Subject to sub-clause 29.3 hereunder until the termination of the trust, the trustees shall apply all or so much of the net income of the trust as they may deem fit for the benefit of one or more of the following beneficiaries and if more than one, in such shares and in such proportions as the trustees may from time to time in their sole and absolute discretion determine, provided that if at any time the income of the trust is insufficient for the vocational training and all reasonable pleasures of any beneficiary, the trustees may utilize and apply so much of the capital of the trust for these purposes as they may from time to time deem fit; 29.2.1 the donees; 29.2.2 any dependant or any spouse or former spouse of any of the donees whom the trustees may select for the purposes hereof whether directly or indirectly;             Without in any way limiting the generality of the trustee's rights to pay or apply net income of the trust as hereinbefore set out, they shall be entitled to utilize and apply such income for the maintenance, education, support, vocational training and/or reasonable pleasures and generally for such purposes as may in their sole and absolute discretion be considered to be in the interests of the donees or other beneficiaries concerned. [7]      The second result of Mr. ...