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Thus the provisions of Schedule III which contain these exemptions are independent, and although it may be useful to compare them, they must ultimately be considered and applied separately. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Inland Revenue Commissioners, [1958] 1 All E.R. 406, Lord Denning said that in understanding a statute he considered specific instances. ...

However, during the years under appeal the appellant claimed capital cost allowance on the plaza, an indication that it considered the plaza to be as a capital asset and not as inventory for sale. ...

A payment received by a tenant from a landlord as an inducement to enter into a lease will be considered in the hands of the tenant as (a) a non-taxable capital receipt where the payment is a reimbursement of part or all of the tenant's capital cost of leasehold improvements within the meaning of Regulation 1102(4); (b) a reduction of those expenses where the payment is a reimbursement of other expenses incurred by the tenant; (c) income where the negotiation of leases is a regular part of the tenant's business operations (e.g. a chain store); (d) a reduction of what would otherwise be the rental expense of the tenant where the payment is a rebate of rent for a period of the lease; (e) a non-taxable capital receipt in other cases. ...

Thus, here again, while I cannot state with certainty that the appellant "knowingly" failed to mention the sale of the building on Marlowe Street, I can at least find that this omission must be considered as made "under circumstances amounting to gross negligence". ...

Reviewing this recent case law, I feel that in the instant case it can be considered that an employee performing the appellant's duties was implicitly required by contract to provide his own car in order to achieve the success necessary to his continued employment and promotion. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

., considered subsection 22(9) of SOR/85-2277 in relation to the effective date of the amendment to subsection 5300(1)(a) of the Regulations which deals with scientific research tax credits in the calculation of the instalment base for individuals. ...

., [1964] C.T.C. 294,64 D.T.C. 5184, Cattanach, J. of the Exchequer Court of Canada (as it then was) considered the application of subsection 8(1) of the Act, which for the purposes of the case at bar, is identical to the current subsection 15(1) of the Act. ...