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The Parties considered, in the alternative, the application of paragraph 8(1) (f), but for the reasons that follow it will be unnecessary for me to address that provision. ...

., [1984] C.T.C. 387, 84 D.T.C. 6374 (F.C.T.D.) at 405 (D.T.C. 6389): It is a rule of construction that, where in the same Act, and in relation to the same subject matter, different words are used such choice of different words must be considered intentional and indicative of a change in meaning or a different meaning. ...

This would indicate that the Court felt that all factors should be considered as a group and no one factor should determine the existence of a source of income. ...

The entire investment picture should be considered (Smith). 12.            ...

" It therefore is not really important whether the $15 million is to be considered as taxes or not, although I would find that it was. ...

Even though reserves carried over from 1987 transactions are not expressly mentioned in subsection 110.6(2.1), Parliament was aware at the time the legislation was passed that the Department of Finance considered the enhanced deduction to apply to 1987 transactions occurring after 17 June 1987 only in respect of reserves carried over into subsequent years. ...

If resort to extrinsic material of this kind, or to the legislative history, were considered useful, then the most helpful material would be the amendments made to section 1400 in 1990 and 1996. ...

Owen J. agreed that the undertaking of unanimity at directors’ meetings which he considered was required by clause 11 might be contrary to public order but that it was not necessary to decide this since the clause was severable from the other provisions of the agreement to which he gave full effect. ...

The Queen [5], the Supreme Court of Canada considered the distinction between income from a business and income from property. ...

Through the years, of course, courts have attempted to express certain principles which should be considered whenever the perennial question came up. ...