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" Even if the alleged indirect use could be considered, the income on the preserved assets was less than 10% of the interest on the borrowed funds. ...

The present charges were similar to those considered in Ontario Home Builders' Association v. ...

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. ...

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. ...

Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership the shares of a subsidiary of a corporation are not owned “indirectly” by the shareholders of that corporation Whether a corporation (the Western Company) was related to its two equal corporate shareholders (the Alberta Company and the Saskatchewan Company) under s.36(4)(b)(iii) of the 1948 Act turned, in part, on whether the related individuals owning all the shares of the Alberta Company and the Saskatchewan Company were to be considered as “owning] directly or indirectly” the shares of the Western Company. ...

Hogan J. found that the general inclusion of "superannuation or pension benefits" at the beginning of s. 56(1)(a)(i) did not mean that clauses (A)-(C.1) were confined to only amounts that were superannuation or pension benefits- in the present case, clause (C.1) meant that the taxpayer was required to include in income an amount paid in redeeming a foreign retirement arrangement, regardless of whether that amount would normally be considered a superannuation or pension benefit (para. 35). ...

However, we are unable to say that the amount of the penalty, considered against all the relevant circumstances, is such a compelling factor in Mr. ...

Miller J. found that even if he considered that the primary purpose of Nowsco in incurring these fees was to maximize shareholder value, this purpose did not take the inputs outside the realm of commercial activity for purposes of s. 169 given that a public company will suffer adverse financial consequences if it does not behave as commercially expected, and there was a secondary purpose of maintaining the ongoing viability and economic health of the company. ...

By virtue of this definition, a single operation is to be considered as a business although it is an isolated venture entirely unconnected with the taxpayer's profession or occupation... ...

Even though that municipality results from a merger of three former cities, the meals eaten within it cannot, in my view, be considered to have been eaten away from the municipality where the employer's establishment was located, or away from the metropolitan area where it was located. ...