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An individual ("K.C. Irving") who controlled the taxpayer and an arm's length supplier of Middle East crude ("Socal") sought to share the...

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Consolidated-Bathurst insured various risks with arm's length Canadian demestic insurers, who reinsured all but a small percentage of those risks...

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An arrangement under which a Bermudan affiliate of the taxpayer purchased aluminium from Alcan, and then sold the aluminium to the taxpayer at a...

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"[W]here provisions of the Income Tax Act have the obvious purpose of encouraging taxpayers to enter into an expenditure of a particular kind...

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"Where the facts reveal no bona fide business purpose for the transaction, s.[245(1)] may be found to be applicable depending upon all the...

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The taxpayer was not precluded from deducting capital cost allowance in respect of a portion of the purchase price paid for a motion picture film...

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S.245(1) is "directed not only to sham transactions but to something less as well where the expense, although real, would unduly or artificially...

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The taxpayer's president had the company pay substantial bonuses to its employees, and persuaded them to donate a large portion of the bonuses to...

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A Bermudan affiliate of the taxpayer purchased crude oil at a price that was less than 90% of its fair market value and resold the oil to the...

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S.66 provided favourable treatment for the deduction and taxation of capital amounts in order to encourage taxpayers to put money into resource...

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A partnership of two dentists determined that the value of administrative services performed by them was $20,000, and 'by means of' appropriate...

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"A disbursement or expense made or incurred" does not include capital cost allowance.

A fee of $61,317 which a subsidiary paid to its parent for services that the parent (primarily in the person of its shareholder and officer)...

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A company made contributions to a pension plan toward the current and past services of certain of its employees (mainly the company's principal...

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"The word 'disbursement' in common parlance means 'money paid out, an expenditure' and the word 'expense' also in common parlance means 'money out...

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The taxpayer, which carried out seismic surveys primarily on its own account and then sold the information so obtained to other companies, was...

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The taxpayer acquired depreciable assets for a price less than their fair market value as part of a series of dividend-stripping transactions that...

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The taxpayer hotel company, in order to soak up losses in a sister company ("Vernon") transferred an employee who had been washing cars on the...

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A cash-basis farmer purchased cattle from a cattle company at the end of his taxation year on the understanding that the cattle company would...

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A 15% management fee paid by a law firm to its related administrative services company was deductible in light of a finding that genuine business...

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