The Queen v. Derbecker, 84 DTC 6549, [1984] CTC 606 (FCA) -- text
Hugessen, J [ORALLY]:—Subparagraph 40( l)(a)(iii) of the Income Tax Act allows a taxpayer to take a reserve
Hugessen, J [ORALLY]:—Subparagraph 40( l)(a)(iii) of the Income Tax Act allows a taxpayer to take a reserve
Rouleau, J:—The issue is whether money paid as additional charges by the plaintiff to its parent corporation in Germany was interest paid on outstanding debts to specified non-residents within the meaning of subsections 18(4) and (5) of the Income Tax
The Associate Chief Justice:—In these actions, both the Crown and the taxpayer, Chrapko, appeal from decisions of the Tax Review Board concerning assessments for Chrapko’s 1977 taxation year, one related to a disputed classification of income, the
Steele, J:—This is an appeal by the Crown by way of stated case from the conviction of the respondent on charges of unlawfully evading payment of income taxes for the years 1979, 1980 and 1981. The trial was based primarily on an agreed
J Holland, J:—This is an appeal from an order made in a garnishee proceeding and involves the method by which the judge below calculated the amount due to the debtor by his employer. The complication which exists is that the employer,
Rothman, JA:—This is an appeal by the Deputy Minister of Revenue of Quebec from a judgment rendered by Judge Louis-Philippe Bouchard, a judge of the Provincial Court, District of Quebec, on March 8, 1984, dismissing the Deputy Minister’s objection to the
Muldoon, J:—The parties here have agreed to submit a special case in lieu of trial and have presented an agreed statement of facts followed by a question of law. Their agreed statement of facts runs as follows:
Robins, JA:—This is an appeal by the Minister of Revenue (“the Minister”) from a judgment pronounced on December 8, 1982, which allowed an appeal by Mattabi Mines Limited (“Mattabi” or “the Company”) from a decision of the Minister made pursuant to
Reed, J:—The plaintiffs claim in this case is an appeal from the assessment for income tax for the 1950 taxation year. I will first summarize the facts. In 1950, the plaintiff acquired shares in Quesabe Mines Limited in his own name and in his wife’s
Pratte, J [ORALLY]:—We have not been persuaded that the decision of the Trial Judge should be interfered with. The appeal will therefore be dismissed with costs.