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Their case was very carefully considered and it seemed to my colleagues and myself that it was a fair case they had put forward. ...

However, the offices were not considered entirely suitable for use by the Appellant in their then-existing state. ...

As a pure legal matter, this property was situated at the office of DIAND where the respondent could legally claim the payment of his salary. [10]            However, Courts have developed a purposive approach in construing the personal property exemption under the Indian Act whereby this situs can nevertheless be considered to be on a reserve where it can be shown through relevant connecting factors that the income earned by an Indian is so linked to a reserve that its taxation would result in "the erosion of the entitlement of the Indian qua Indian on a reserve" (Williams v. the Queen, [1992] 1 S.C.R. 877 at paragraph 37). ...

While the existing case law deals with interest income derived from cash investment certificates as opposed to royalty income derived from mineral interests, money cannot be equated with goods and services themselves and therefore it is logical that in order for interest to be considered active business income the underlying cash must be shown to have a close connection with the business. ...

Actually, she did not even have the supporting documents for these costs because the accountant had not considered them to be capitalizable costs. ...

I underscore these two points in that passage: (i) the deemed benefit under paragraph 7(1)(a) was in fact included in computing the plaintiff's cost of the option shares pursuant to section 9 of the Act; and (ii) McNair, J. considered that it was both fair and proper for the Minister to determine the plaintiffs business profits in respect of the shares in that way. [5] The appeal is allowed and the matter is referred back to the respondent for reconsideration and reassessment on the basis that what happened regarded the 5,000 shares renders the matter an adventure or concern in the nature of trade. ...

But he considered this next step necessary: The Fair Market Value of the tangible assets must be deducted from this amount to determine the intangible asset value. ...

The fact that the $47,500 may have been at risk to cover debts of the partnership cannot give it the quality of a capital contribution any more than a loan to the partnership can be considered as a part of its capital. ...

As clarified in written submissions received from the respondent following the hearing, these amounts do not have to be considered separately because they are part of the child tax benefit in section 122.61 of the Act.   ...

the above dates shall be considered strict time limits. In the event of the Appellants’ non-compliance with such time limits, the Respondent shall be free to bring a motion in writing to dismiss the appeals for the Appellants’ failure to comply with the terms of this Order.   5.       ...