Special Risks Holdings Inc. v. The Queen, 86 DTC 6035, [1986] 1 CTC 201 (FCA) -- text
Pratte, J.:—This is an appeal from a judgment of the Trial Division dismissing an appeal from income tax reassessments under Part III of the Income Tax Act.
Pratte, J.:—This is an appeal from a judgment of the Trial Division dismissing an appeal from income tax reassessments under Part III of the Income Tax Act.
Addy, J.:—The present application is for certiorari pursuant to section 18 of the Federal Court Act to quash an assessment of the applicant for income tax purposes made by notice of assessment dated the March 26,1985
Joyal, J.:—On September 28, 1976, in Montreal, a settlement out of court was negotiated between the plaintiff herein and a Crown-owned Newfoundland Company called Newfoundland Steel Corporation (NESCO). The settlement was for damages for breach of contract. The
Denault, J. [TRANSLATION]:—The plaintiff Danzas S.A., with its head office located in Switzerland, and its Canadian subsidiary are companies specializing in the carriage of air freight, and they are claiming from the defendant damages amounting to U.S. $656,952.70,
Denault, J.:—The plaintiff is appealing from a decision of the Tax Court of Canada. The facts in this matter are the same as those of a co-employee Ray Bastien (T-507-85) and since these actions were heard together on common evidence, the Court
Pratte, J.:—The only issue on these appeals is whether the payment of a sum of $65,000 to a partnership named Grovedale Realty Co. (Grovedale) gave rise to a Capital gain in a like amount.
Dubé, J.:—The issue to be resolved in this matter is whether the amount of $560,650 paid to the plaintiff by the United States Fire Insurance Company (“U.S. Fire’) on June 9, 1980 constituted income of the plaintiff, as assessed by the Minister
Cory, J.A.:—The Attorney General of Canada has brought this appeal from a judgment dated February 4, 1985 which set aside a “retention order” made by the Honourable Judge Warrender pursuant to the provisions of subsection 231(2) of the Income
McNair, J.:—This is an appeal by the plaintiff from the Minister’s reassessments with respect to the 1978,1979 and 1980 taxation years whereby benefits received on the exercise of certain stock options were taxed as income in the plaintiff’s hands and
Reed, J.:—These reasons pertain to several motions (two brought by the plaintiff, one brought by the defendant, Amway Corporation), which were all heard together and which are intertwined. A fourth was also heard at the same time but because further