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Therefore, it is convenient to deal with that issue now so that it need not be considered at the new hearing ...

However, it must be remembered that what is recorded as an obligation for accounting purposes may not be considered an absolute liability at law if a creditor with a legally enforceable claim cannot be identified. [25]            In my view, the requirement that General Motors accrue amounts in the Contingency Fund did not create an absolute liability in 1995. ...

In a similar vein, Mr Justice Dickson lists, again at 314 [5215], a number of criteria which might be considered in the determination of a “reasonable expectation of profit”, such as “... 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.” ...

The amount had to be considered as an outlay for gaining income from an adventure in the nature of trade and not as an outlay or loss on account of capital. ...

At the same time, the taxpayer agreed that if the Liberty building sold for less than $3.75 million the taxpayer’s debt to each would not be considered to have been repaid. ...

The CCRA then considered whether it was appropriate in the circumstances to exercise its discretion to cancel or reduce the penalty and interest charges under the "fairness legislation" of the Income Tax Act, R.S.C. 1985 (5th Supp.), c. 1 (the "Act"). ...

As well OMC had recently indicated that its relationship with the plaintiff would continue indefinitely because, according to Bell, OMC personnel had told him that the plaintiff company was doing the job in Newfoundland better than the management at OMC considered it could do it. ...

In McCutcheon, supra, the Federal Court considered high proportions of interest income in relation to overall income important in concluding that the deposits there in question were not business income. ...

The decision in Rose and the comments of the former Chief Justice supra in that decision must be considered in the light of the pleadings in that case. ...

Background [2]                 At issue is whether the acquisition of specified assets by a partnership is subject to the arm's length rule set out in paragraph 69(1)(a) of the Income Tax Act (the Act), and if so whether the Tax Court Judge correctly held that the transaction in issue did not take place at arm's length. [3]                 The Tax Court Judge held that the facts and issues in the appeal had been considered and conclusively disposed of in Madsen v. ...