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  [21]     The Court also considered in Pepper and Mymryk the constructive receipt provisions of subsection 56(2) of the Income Tax Act. ...

  [28]     Therefore, the evidence as a whole contains too many contradictions, uncertainties and unanswered questions, such as how the business operated when the Appellant was not working there, to allow me to conclude that the Minister's decision is unreasonable in the circumstances and in light of all the factors to be considered. ...

In my view, the Appellant failed to understand the distinct personality a corporation has apart from shareholders at law, and has also failed to recognize that the Workers are to be evaluated as individuals and not as a unit when considered in their separate legal roles as employees ...

The Queen, 94  DTC  1735, Rip J. of this Court allowed the appellant's appeal, concluding that the amounts paid to a babysitter for the seven-day period immediately preceding the appellant's return to work should be considered to be child care expenses. ...

Given the impact on the assessment, the reductions should be considered an admission favourable to the Appellant ...

He confirmed his diagnosis of attention deficit disorder and associated behavioural issues and according to his expert testimony he considered that Matthew could benefit from this type of structured setting.  ...

(ii)                Since Les Produits Déli‑Bon 2000 Inc. was the purchaser of the company's shares, the Appellant argued that the payments of US$320,000 and US$380,000 made out of the company's own funds for the purchase of the shares must be considered advances made by the company to Les Produits Déli‑Bon 2000 Inc. rather than to him and Mr.  ...

The Queen, [1983] 1 S.C.R. 29, income earned by an Aboriginal can be considered personal property of an Indian for the purposes of section 87 of the Indian Act. ...

The dividends cannot be considered salary. The second problem is that the declaration and payment of a dividend cannot be likened to a salary or payment for services rendered. ...

Paragraph 21 refers to the McKimmon decision and sets out certain criteria which include item (d):   (d)        Whether the payments purport to release the payer from any future obligations to pay maintenance — If there is such a release the payments will normally not be considered an allowance for maintenance.   ...