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The Queen, 2002 DTC 2110 (TCC)-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition The taxpayer, which was a Canadian natural gas producer, received a lump sum as compensation for the losses it was considered to have suffered as a result of the cancellation of long-term natural gas supply contracts it had entered into with one purchaser ("A&S"), with the result that it thereafter was to sell its natural gas under short-term gas supply contracts and under a continuation of modified versions of existing sales arrangements. ...

Even if this conclusion were incorrect, the taxpayer would have been considered to have acquired separate depreciable assets (i.e., the new engines, generators and hydraulic, electronic and navigational equipment and running gear installed in the vessel). ...

When paragraph 95(6)(b) is triggered, it affects whether a particular share acquisition or disposition should be considered when computing income. ...

He stated (at para. 28): A fraudulent scheme from beginning to end or a sting operation, if that be the case, cannot give rise to a source of income from the victim's point of view and hence cannot be considered as a business under any definition. ...

Woods J. stated that this argument would assist the taxpayer "only if the cessation of [the] business was considered to be temporary sometime after December 31, 2006" (para. 13). ...

.), Steele J. stated: "In considering what is the preponderating business, all aspects of the business must be considered and weighed to determine its real function. ...

Consequently, the Appellant's understanding and interpretation, which is reasonably supported by the factual matrix and law, ought to have been known to and considered by the Respondent when accepting the Appellant's settlement offer. ...

Parliamentary history to be consulted only in limited circumstances A statement by the Financial Secretary to the Treasury when the Finance Bill 1976 was being considered clearly indicated that a construction which otherwise would have been given by the House of Lords to section 63 of that Act did not accord with Parliament's intention. ...

Bowie J. found that the plans had not been entered into with considered judgment as to their commercial benefit to the taxpayers' firm: the amounts paid to the plan were set without regard to the actual benefit of the services; no attempt was made to seek competing bids from actual medical insurance providers; and the plan was not extended to non-spouse employees. ...

The Queen, 95 DTC 127, [1995] 1 CTC 2122 (TCC)-- summary under Subsection 227(9.4) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(9.4) It was found that the taxpayer, which was the prime contractor for the construction of a hotel, effectively established "total control and dominion over the funds used to pay the wages of the workmen" of a subcontractor that had fallen into financial difficulty (p. 133), with the result that the taxpayer was to be considered the person that was paying the employees' wages. ...