Continental Bank of Canada v. The Queen, 94 DTC 1858, [1995] 1 CTC 2135 (TCC), aff'd at 98 DTC 6501 (SCC) after being, rev'd 96 DTC 6355 (FCA) -- text

Bowman J.T.C.C.:—Continental Bank of Canada (”CB”) appeals from assessments for its 1986 and 1987 taxation years. Its wholly owned subsidiary, Continental Bank Leasing Corporation (”CBL”) appeals from an assessment for its 1987 taxation year. The appeals were heard together.

Alberta Energy Co. Ltd. v. The Queen, 95 DTC 220, [1995] 1 CTC 2111 (TCC), aff'd 98 DTC 6007 (FCA) -- text

Bonner J.T.C.C.:-This is an appeal from an assessment of income tax for the appellant’s 1984 taxation year. During that year, the appellant entered into an Agreement in writing (the ’’Farmout agreement") with Esso Resources Canada Ltd. ("Esso"). Under the

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