Hargrave P.:—This action arises out of a 1979/1980 land transaction participated in jointly by the plaintiff and eight other individuals. The plaintiff appealed the Revenue Canada assessment to the Tax Court of Canada in September of 1984 and after a history
Cory J.:—In this matter I have had the pleasure of reading the careful reasons of my colleague La Forest J. I am in complete agreement with his view that the governing principles to be applied in this case are set out in the reasons of this Court in Manitoba (Attorney General) v. Metropolitan Stores Ltd., [1987] 1 S.C.R. 110, 38 D.L.R. (4th) 321, and in RJR-MacDonald Inc. v. Canada (Attorney General), [1994] 1 S.C.R. 311, 111 D.L.R. (4th) 385.
Stone J.A.:—The appellant seeks to have an order of the Trial Division of September 29, 1992 set aside on the basis of alleged errors committed by that division in striking out his statement of claim which was filed July 8, 1992. The essence of
Jerome A.C.J.:-This is an appeal from a judgment of the Tax Court of Canada dated April 3, 1992. The issue is whether the plaintiff validly elected, pursuant to subsection 15(5) of the Income Tax Act, R.S.C. 1952,
Rouleau J.:-This is an appeal from a decision of the Tax Court of Canada dated April 10, 1991 (unreported). At issue is whether the plaintiff had benefits conferred on him qua shareholder for the 1985, 1986, and 1987 taxation years, and
Mahoney J.A.:-This is an appeal from a reported decision of the Tax Court of Canada ([1993] 2 C.T.C. 2252, 93 D.T.C. 1020). The issue is whether $1,000,000 received by the respondent as an inducement to enter into a lease was taxable to him as
Noël J.:—Cyril Cecil Kane ("the plaintiff’) appeals from the decision of the Tax Court of Canada whereby the reassessments issued by the Minister of National Revenue with respect to his 1979, 1980 and 1981 taxation years were upheld.
Whetung J. (orally)-The two co-accused in this matter are charged with offences under the Income Tax Act. For the purpose of the present ruling, it is not necessary that I consider the substantive elements of the offences alleged. If ultimately convicted, the maximum penalty for each offence could be fines of 200 per cent of the tax sought to be evaded, and a jail term of two years.
Gibson J.:—These reasons arise out of two applications by the respondent, Andre Rouleau, brought pursuant to subsection 225.2(8) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), to review two authorizations, commonly known as
