Roseland Farms Ltd. v. Her Majesty the Queen, [1992] 2 CTC 398, 93 DTC 5008 -- text
McGillis, J. (orally):—These are my reasons for judgment in the matter of Roseland Farms Ltd. and Her Majesty the Queen.
McGillis, J. (orally):—These are my reasons for judgment in the matter of Roseland Farms Ltd. and Her Majesty the Queen.
Desjardins, J.A.:—In 1981 the appellant was a Canadian resident employed by a Canadian company, Alcan Aluminium Ltd., with which he held the position of "Chief Financial Officer”. On November 30, 1981 his employer agreed to grant him share purchase options
Ground, J.:—This is an application by the Attorney General of Canada for an order declaring that the exercise of statutory collection remedies by the Minister of National Revenue (the "Minister") pursuant to certain sections of the Income Tax
MacKay, J.:—This action, an appeal of a decision of the Tax Court of Canada rendered July 11, 1989, came on for hearing on June 27, 1991, in Halifax. At the commencement of the hearing, I allowed an application to amend the statement of
Hugessen, J.A.:—This is an appeal from a decision of the Trial Division allowing a motion by the respondents under Rule 419(1)(a) and striking out the appellants' statement of claim.
Stone, J.A. (Isaac, C.J., and Heald, J.A., concurring):—This is an appeal from a judgment of McNair, J. rendered January 16, 1990, whereby the respondent's action by way of appeal from a judgment of the Tax Court of Canada
McKinnon, J:— Total Petroleum Canada Ltd. ("Total") contracted with Degenhardt Pipeline Contractors Ltd. ("Degenhardt") for the construction of two gas pipelines in northern British Columbia. Degenhardt "completed" the project but left the area owing subcontractors in excess
Sheppard, J.:—The accused are charged with income tax evasion. The case raises issues which Crown counsel acknowledged are “novel”. The Crown alleges that the accused, particularly Frank Fogazzi, misappropriated money entrusted to them for investment purposes. According to
Armstrong, J.: This decision follows a hearing under Queen's Bench Rule 188.
Catzman, Galligan and Arbour, JJ.A.:— It is not disputed that the liability for income tax, which was ultimately discharged by the respondent, was that of the appellant. Regardless of the reason why the respondent failed to withhold that