Thyssen Canada Ltd. v. The Queen, 84 DTC 6539, [1984] CTC 600 (FCTD), rev'd 87 DTC 5038, [1987] 1CTC 112 (FCA) -- text

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 Queen v. Chrapko, 84 DTC 6544, [1984] CTC 594 (FCTD), rev'd 88 DTC 6487, [1988] 2 CTC 342 (FCA) -- text

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

The Royal Bank of Canada v. The Queen, 84 DTC 6439, [1984] CTC 573 (FCTD), aff'd 86 DTC 6390, [1986] 2 CTC 211 (FCA) -- text

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:

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