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Furthermore, the taxpayer was unsuccessful in its submission that because 922 was liable for withholding tax under s. 215(3), the taxpayer should be considered to be relieved of liability under s. 215(1). ...

Furthermore, the taxpayer was unsuccessful in its submission that because 922 was liable for withholding tax under s. 215(3), the taxpayer should be considered to be relieved of liability under s. 215(1). ...

., "all of the tasks, activities, or actions that an employer may require an employee to perform" (p. 1746)) required him to remain in the City one week out of every three, and in appropriate circumstances rent could be considered to be a travel expense, including here where he stayed in the City for the benefit of his employer and as required by it. ...

Hogan J. found that the resulting trust was a bare trust, in which the corporations could reasonably be considered to have acted as mere agents for the taxpayer. ...

Hogan J. found that the resulting trust was a bare trust, in which the corporations could reasonably be considered to have acted as mere agents for the taxpayer. ...

Hogan J. found that the resulting trust was a bare trust, in which the corporations could reasonably be considered to have acted as mere agents for the taxpayer. ...

Hogan J. found that the resulting trust was a bare trust, in which the corporations could reasonably be considered to have acted as mere agents for the taxpayer. ...

But when the leasing transactions are considered independently, London Life is supplying the leasehold improvements to the landlords for the consideration of the leasehold improvement allowances. ...

Accordingly, Archambault J. rejected a submission of the taxpayer's counsel that shares owned by a subsidiary of a public corporation should not be considered to be treated as shares that tainted the corporation's mooted status as a CCPC because the right to control the voting rights of those shares had been transferred to a Canadian-resident non-public corporation for a six-year period. ...

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. ...