In the Matter of the Bankruptcy of Country Inns Inc., [1995] 1 CTC 75, 94 DTC 6650 -- text

Cote J. (Hetherington and Irving, JJ.A., concurring):—

A. The issue

A panel of this Court heard three appeals together. In each, one party is The Queen, as represented by the Minister of National Revenue (here called the Minister). And in each case the other party is a bank or the Alberta Treasury branches. Each appeal is a priority contest between the Minister’s garnishee summons, and a general assignment of book debts to the bank or Treasury branch.

Edwin J. Byram v. Her Majesty the Queen, [1995] 1 CTC 66, [1995] DTC 5069 -- text

Wetston J.:—This is an appeal from a reassessment of income by the Minister of National Revenue, dated June 28, 1988, in respect of the plaintiff’s 1982, 1983, 1984, 1985 and 1986 taxation years. Each court file corresponds to one taxation year; the

Khwaja Gulzar Ahmad v. Her Majesty the Queen, [1995] 1 CTC 58, 95 DTC 5123 -- text

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

The Minister of Revenue of Quebec, the Deputy Minister of Revenue of Quebec, the Attorney General of Quebec and Robert Paulin v. 143471 Canada Inc., Leonardo Arcuri Francesco Milioto, Antonio Facchino, John A. Paoletti, Santo Gracioppo and Casmiro C. Panarello, [1995] 1 CTC 27 -- text

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.

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