Reed, J.:—The issue in this case is a narrow one. It involves the correct interpretation of subparagraph 39(1)(c)(v) of the Income Tax Act’ [1] and, in particular, how that subparagraph relates to subsection 85(4) of
Addy, J.:—The plaintiff appealed against an income tax assessment issued by the defendant against it for the 1979 taxation year. Another action was also- instituted pursuant to which it contested the assessment for 1980. Both actions were ordered to be
Teitelbaum, J.:—The plaintiff, Mohawk Oil Co. Ltd. (Mohawk) carries on the business of distributing and marketing automotive fuels and convenience goods and oil and gas exploration. On November 27, 1978, Mohawk entered into a purchase agreement with Phillips
Hugessen, J.A.: —We are all of the view that this appeal must fail and that the appellant was properly assessed under sections 212 and 215 of the Income Tax Act to pay withholding tax on interest paid by it to its
Hugessen, J.A.:—The appellants, who are land developers, entered into a certain number of 50-year leases of residential lots with an option to purchase exercisable by the lessees at any time during that term. At issue in these appeals is the trial
Addy, J.:—The facts in this case are not in dispute. There have been documents filed on consent as Exhibit 1, and in the pleadings the facts mentioned by the plaintiff on which he relies have been largely admitted by the defence.
Blair, J.A.:— The issue in this appeal is whether taxpayers can claim relief under the Canadian Charter of Rights and Freedoms if they are less favoured than other taxpayers under the Income Tax Act,
Desjardins, J.A.:—This is an appeal from a decision of the Trial Division whereby Collier, J. concluded that interest amounts paid on borrowed money used to purchase a family dwelling were deductible from the taxpayer's income for the taxation years 1980,
Rouleau, J.:—The plaintiff, 335114 Alberta Ltd., a judgment creditor of the plaintiff Lan-Mar Developments Ltd. ("Lan-Mar") and also the beneficial owner of all of the issued and outstanding shares of Lan-Mar, is seeking to recover from the Minister of
Joyal, J. [Translation]:—The facts in this matter are as follows.
