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The two relevant provisions of the Act read as follows: Subparagraph 256(1)(b): For the purposes of this Act, one corporation is associated with another in a taxation year if at any time in the year, (b) both of the corporations were controlled, directly or indirectly in any manner whatever, by the same person or group of persons; Subsection 256(5.1): For the purposes of this Act, where the expression “controlled, directly or indirectly in any manner whatever,” is used, a corporation shall be considered to be so controlled by another corporation, person or group of persons (in this subsection referred to as the “controller”) at any time where, at that time, the controller has any direct or indirect influence that, if exercised, would result in control in fact of the corporation, except that, where the corporation and the controller are dealing with each other at arm’s length and such influence is derived from a franchise, licence, lease, distribution, supply or management agreement or other similar agreement or arrangement, the main purpose of which is to govern the relationship between the corporation and the controller regarding the manner in which a business carried on by the corporation is to be conducted, the corporation shall not be considered to be controlled, directly or indirectly in any manner whatever, by the controller by reason only of such agreement or arrangement. ...

This fact is an incentive for him to maintain a good business and to work accordingly. 3.06 Claude Potvin, an auditor with the Department of Revenue Canada for 12 years, explained that many expenses were disallowed in the appellant’s case: (a) they were considered as personal, mainly restaurant expenses of $4 to $12; (b) the vouchers bore no date; (c) some vouchers were filed in duplicate; or (d) they were considered ineligible, such as home office expenses, golf expenses and unjustified travel expenses. 3.07 Mr. ...

The rule has been considered in two decisions of the Tax Court. In Austin v. ... It was also poorly researched, ill-considered and virtually impossible to support in law. ...

There is no doubt that the amounts thus paid out cannot be considered, for the purposes of paragraphs 56(l)(i>), 56(1)(c), 60(b) and 60(c) of the Act, to be alimony or another allowance payable on a periodic basis paid by Mr. ... Furthermore, by application of subsection 56(12), these amounts could not be considered to be alimony since the appellant had no discretion as to the use of the amounts paid out. ...

Justice Dickson, as he then was, considered what the words “reasonable expectation of profit” mean. ... 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. ...

Those portions of section 122.6 of the Income Tax Act respecting this question read, “eligible individual” in respect of a qualified dependant at any time means a person who at that time (a) resides with the qualified dependant, (b is the parent of the qualified dependant who primarily fulfils the responsibility for the care and upbringing of the qualified dependant, (c) is resident in Canada, (d) is not described in paragraph 149(1)(a) or (b), and (e) is, or whose cohabiting spouse is, a Canadian citizen or a person who (i) is a permanent resident (within the meaning assigned by the Immigration Act), (ii) is a visitor in Canada or the holder of a permit in Canada (within the meanings assigned by the Immigration Act) who was resident in Canada throughout the 18-month period preceding that time, or (iii) was determined before that time by the Convention Refugee Determination Division of the Immigration and Refugee Board to be a Convention refugee, and, for the purposes of this definition, (f) where the qualified dependant resides with the dependant’s female parent, the parent who primarily fulfils the responsibility for the care and upbringing of the qualified dependant is presumed to be the female parent, (g) the presumption referred to in paragraph (f) does not apply in circumstances set out in regulations made by the Governor in Council on the recommendation of the Minister of National Health and Welfare, and (h) factors to be considered in determining what constitutes care and upbringing may be set out in regulations made by the Governor in Council on the recommendation of the Minister of National Health and Welfare; “qualified dependant” at any time means a person who at that time (a) has not attained the age of 18 years, (b) is not a person in respect of whom an amount was deducted under paragraph (a) of the description of B in subsection 118(1) in computing the tax payable under this Part by the person’s spouse for the base taxation year in relation to the month that includes that time, and (c) is not a person in respect of whom a special allowance under the Children’s Special Allowances Act is payable for the month that includes that time. ... For the purposes of paragraph (h) of the definition of ‘eligible individual’ in section 122.6 of the Act, the following factors are to be considered in determining what constitutes care and upbringing of a qualified dependant: (a) the supervision of the daily activities and needs of the qualified dependant; (b) the maintenance of a secure environment in which the qualified dependant resides; (c) the arrangement of, and transportation to, medical care at regular intervals and as required for the qualified dependant; (d) the arrangement of, participation in, and transportation to, educational, recreational, athletic or similar activities in respect of the qualified dependant; (e) the attendance to the needs of the qualified dependant when the qualified dependant is ill or otherwise in need of the attendance of another person; (f) the attendance to the hygenic needs of the qualified dependant on a regular basis; (g) the provision, generally, of guidance and companionship to the qualified dependant; and (h) the existence of a court order in respect of the qualified dependant that is valid in the jurisdiction in which the qualified dependant resides. ...

The Minister considered the loan to be income under subsection 15(2). ... I agree with the following passage from the appellants’ “Written submission”: [TRANSLATION] Written submission: the Federal Court of Appeal considered what interpretation should be given to the term “reasonable assistance’’ in the context of subsection 15(2). ...

“adjusted cost basis” to a policyholder as at a particular time of the policyholder’s interest in a life insurance policy means the amount determined by the formula (A + B + C + D + E + F + G + G.l)- (H + I + J + K + L) where A is the total of all amounts each of which is the cost of an interest in the policy acquired by the policyholder before that time but not including an amount referred to in the description of B or E, The notice of confirmation by the Minister of National Revenue (“the Minister”) confirms the appellant’s assessment for the following reason: [TRANSLATION] The notice of objection you filed in respect of the income tax assessment made for the 1995 taxation year was carefully considered in accordance with subsection 165(3) of the Income Tax Act. ... In making the assessment, the Minister considered the facts described in paragraph 9 of the Reply to the Notice of Appeal to be true. ...

A person living with a de facto spouse did not lose his right to claim the credit under paragraph 118(I)(£>) simply because he was not considered to be married. ... Côté, who had lived with Patricia Tessier for several years before 1993, and who was the father of her two children, was considered to be married to Ms. ...

In making the assessment, the Minister considered the following facts, inter alia, to be true: (a) Francis Bouchard, the appellant’s father, had a tax liability of $22,691.91 from the 1984, 1985, 1986 and 1987 taxation years; (b) On February 12, 1987, Francis Bouchard and his two sons, namely the appellant and Sylvain Bouchard, signed an agreement under which the father transferred 30 of his common shares in Garage Francis Bouchard Inc. to his above-mentioned two sons for a total consideration of $93,000; (c) on the same date, the father then assigned the said sale price of $93,000 to his two sons, namely the appellant and Sylvain Bouchard, as a gift; (d) on February 12, 1987, the father, Francis Bouchard (“the transferor”), transferred an assignment of an account receivable of $93,000 to the appellant and his brother Sylvain; (e) at all relevant times, the appellant and the transferor were not at arm’s length; (f) at the time of the transfer, it was specified that the value of the transferred portion was $19,850 for the appellant: (g) at the time of the transfer, the fair market value of the consideration given by the appellant in respect of the property was nil; (h) the total of all amounts that the transferor was liable to pay under the Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year was $22,691.91; (i) Francis Bouchard made an assignment of his property on April 3, 1992. 6. ... Thus, in this case, since Francis Bouchard’s son is an adult, sections 74.1 to 75.1 of the Income Tax Act do not apply in the circumstances; only the disposition of the property should be considered under paragraph 160(1)(J) and in reading subparagraph 160(l)(e)(ii) we should take into account the taxation year in which the property was transferred. ...