Re MNR and Chrysler Canada Ltd., 91 DTC 5526, [1991] 2 CTC 156 (FCTD) -- text
Strayer, J.: —
Strayer, J.: —
Montgomery, J.:—These reasons are issued to advise the profession that, on the basis of a recent ruling of Revenue Canada, the scope of structured settlements has been expanded to apply in appropriate cases to self-insurers.
Joyal, J.: —This is an appeal by the plaintiff from a tax reassessment issued by the Crown with respect to the plaintiff's 1980 tax return. The effect of this reassessment was to add to the plaintiff's income for that year an amount of
Oliver, A.C.J.: —
Côté, J.A. (for the Court): —Here the vendor appellant had some producing resource properties on which it wished to raise money. The purchaser (not a party here) had some tax losses which it wished to sell. They and the
Young, P.C.J. [Orally]:—At the close of the Crown's case, the defence brought a motion for a directed verdict, indicating that the two counts before the court do not apply to the Crown's case and the evidence therein.
Denault, J.:—The opposant, the defendant's wife [1] , is opposing a seizure of immovables by the Minister of National Revenue against the defendant pur- suant to the filing of a certificate on September 28, 1983 ordering him to pay
Robins, Griffiths, Osborne, JJ.A.: — The question in this appeal is whether the factual circumstances are such as to provide a valid basis in law for permitting the appellant to withdraw his guilty plea to the charge of income tax
Muldoon, J.:—In this case are involved very serious considerations about the nature of Canada and whether the State is to be characterized legally and constitutionally as atheistic, secular or theocratic. In fact, the nature of the present proceeding is the
Denault, J::—This is an appeal by the Minister of National Revenue from a decision of the Tax Court of Canada, as well as a cross appeal by the taxpayer. It involves two transactions, the first resulted in the defendant's wife acquiring shares