Can-Am Industrial Auctioneers Inc. v. Rompkey, 84 DTC 6151, [1982] CTC 302, [1982] DTC 6255 (FCTD) -- text
Addy, J:—Devant la cour requête des demandeurs afin d’obtenir une ordonnance:
Addy, J:—Devant la cour requête des demandeurs afin d’obtenir une ordonnance:
Dube, J:—This application is for an order staying the execution of all the judgments or orders granted to the Department of National Revenue against the petitioner.
Smith, DJ:—The plaintiffs in this action are claiming that the reassessment of the estate of William Edward Hillis to income tax for the taxation year 1977 dated May 20, 1980 be vacated. The income tax return for the deceased’s estate for the
Mahoney, J:—The sole issue remaining, after settlement and abandonment of other matters, is whether an amount to provide Atomic Energy of Canada Limited, hereafter “AECL”, with “know-how” and a non-exclusive licence under patents and patent applications relative to
Heald, J:—This is an appeal from a judgment of the Trial Division allowing the respondent’s appeal from a reassessment of income tax made by the Minister of National Revenue in respect of respondent’s 1973 taxation year.
Mahoney, J:—The only issue is whether amounts credited in lieu of dividends in 1972 and 1973 by the plaintiff to the trustees of The Penn Central Transportation Company, a non-resident shareholder carrying on business in Canada, were exempt from withholding
Décary, J:—The issue in this matter is to determine, for the purpose of section 125.1 of the Income Tax Act, if the interest received by plaintiff is Canadian manufacturing and processing profits as defined in paragraph 125.1
Thurlow, CJ:—The principal issue in this appeal is whether the appellant, in the 1977 taxation year, received or enjoyed a benefit in respect of, in the course of, or by virtue of his office, within the meaning of paragraph 6(1 )(a)*
Lambert, JA:—This is an appeal on two points of law under section 25 of the Logging Tax Act. Both points of law relate to capital cost allowance in ascertaining income derived from logging operations.
Walsh, J:—Two motions for dismissal of oppositions made by the respective opposants came on for hearing and were heard simultaneously. The Minister of National Revenue obtained judgment against defendant for amounts withheld by it from employees by virtue of