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Instead, the words "it may reasonably be considered" placed a substantial onus on the taxpayer to produce some explanation which is objectively reasonable that none of the purposes was to alter the value of a shareholder's interest". ...

Further, it could be seen that the issue of undue delay was considered in the decision not to waive interest and penalties as the decision referred to the complexity of legal issues involved. ...

Canada, [1998] 1 S.C.R. 795, 98 DTC 6334, [1998] 3 CTC 303-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance no business purpose test In finding that the transactions under consideration had successfully avoided the change-of-control provisions of the Act, Iacobucci C.J. stated (at p. 6350) that "it is well established in the jurisprudence of this Court that no 'business purpose' is required for a transaction to be considered valid under the Income Tax Act, and that a taxpayer is entitled to take advantage of the Act even where a transaction is motivated solely by the minimization of tax". ...

., 80 DTC 6207, [1980] CTC 216 (FCTD)-- summary under Paragraph 256(1)(b) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(b) It was stated, obiter, that where the Court has to decide whether two corporations are associated by reason of being controlled by the same persons or same group of persons, who might be complete strangers and not persons all related by blood, it is de facto control that must be considered, i.e., whether control of the two corporations is in fact exercised by the same group. ...

Addy, J. stated: "Where the development of the basic food product still involves the growing process and natural biological changes as opposed to artificially manufactured foods or mere processing, I do not feel that, generally speaking, the activity would be considered by the general public anything other than agricultural in nature". ...

Joyal J. noted (p. 5326) that "not all sums paid to a person who happens to be a director of a company will automatically be considered income from that office". ...

What the purchaser says on this point must always be considered, but it may not be decisive. ...

The Queen, 2013 DTC 1256 [at at 1435], 2013 TCC 322 (Informal Procedure)-- summary under Eligible Relocation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Eligible Relocation no new responsibilities at current job Favreau J found that the taxpayer's move in 2010, 70 kilometers closer to the place she worked since 1996, was not an eligible relocation because her place of employment could not reasonably be considered a "new work location. ...

Such an allegation could be asserted by her in the Federal Court when the Minister attempted to recover the sums he considered to be payable. ...

Such an allegation could be asserted by her in the Federal Court when the Minister attempted to recover the sums he considered to be payable. ...