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McMurtry C.J.O. stated (at p. 5364) that the "teams' connection with non-Ontario venues and the control of these venues is relatively so transitory that they cannot be considered to be fixed places of business". ...

Although they were not subsidies or forgivable loans, they were "any other form of assistance," which Nadon JA found should be considered to be the case unless "the public authority in question is acting in a business rather than a governance capacity. ...

The Court concluded that in applying the Ramsay principle the composite effect of the arrangement should be considered as the scheme was intended to operate without regard to the contingency that one of the options might not be exercised. ...

Bowie TCJ. found that the first installment (which was at issue) was exempt given that the taxpayer was entitled to receive the second installment only if he performed stipulated services and given that the taxpayer considered that all of the money was being paid to him for playing hockey, and not that part of it was paid simply to sign his name. ...

Rip CJ also noted with approval the principle in Imperial Tobacco that "communications between employees of a company that include legal advice provided by the corporation's lawyer will be considered privileged. ...

Flanigan stated (p. 277): "There are literally hundreds of people who are employed by American corporations who come into Canada and do business, but these people are certainly not considered to be Canadian residents or to have a permanent establishment if they attend at an office in this country to transact their business". ...

The ordinary meaning of the word "liable" ("responsible at law"), the contrasting use of the terms "liable" and "payable" in the relevant provisions and the fact that this interpretation was consistent with an interpretation that the enactment of s. 162(2.1) was intended by Parliament to put some teeth into the filing requirements for non-resident corporations, suggested that a corporation would be considered to be "liable to a penalty" under s. 162(1) even if such penalty was nil. ...

The Queen, 78 DTC 6445 as establishing the proposition that "the question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent businessman" and went on to find (at p. 219) that the taxpayer "did not discharge its burden of proving that the debt was not uncollectible in the year 1982 on the balance of probabilities". ...

., in situations where the audit site was further from her home than from the office of her employer) as being of a non-personal nature given that it would be inefficient for her to go to the office and then to the audit site, and no element of the distance covered when she went from her home directly to an audit site should be considered to be of a personal nature. ...

Fordham found (at p. 249) that the "real purpose" of the agreement was to give the taxpayer the sole right to use the Anne Klein name in Canada and that "anything else was... purely incidental and not to be considered as meriting separate terms of payment". ...