Johnston v. R., 98 DTC 6169, [1998] 2 C.T.C. 262 (FCA) -- text
Létourneau J.A. (Desjardins J.A. concurring):
Facts and Issues
1 These are applications for judicial review of a decision of a Tax Court Judge which denied the Applicant the disability tax credit found in paragraphs 118.3(1)(a.1) and 118.4(1)(c) of the Income Tax Act (the “Act”).
Kowdrysh v. The Queen, 2001 DTC 5221, 2001 FCA 34 -- text
Action by Christians for the abolition of torture v. Canada, 2003 DTC 5394, 2002 FCA 499 -- text
South Wind v. R., 98 DTC 6084, [1998] 1 CTC 265 (FCA) -- text
Linden J.A.:
Cardella c. Canada, 2001 DTC 5251, 2001 FCA 39 -- text
Canada v. Bombardier Inc., 2012 DTC 5088 [at at 7005], 2012 FCA 46 -- text
Hunter v. The Queen, 2001 DTC 907 (TCC) (Informal Procedure) -- text
Willis (Arbeau) v. The Queen, 2012 DTC 1062 [at at 2791], 2012 TCC 23 (Informal Procedure) -- text
Cudd Pressure Control Inc. v. Canada, 98 DTC 6630, [1999] 1 CTC 1 (FCA) -- text
Robertson J.A.:
The primary issue on appeal is whether Judge Sarchuk of the Tax Court of Canada erred in concluding that $2,516,690.00 of notional “rent” could not be deducted by Cudd Pressure Control Inc. in computing the net industrial and commercial profit attributable to its permanent establishment in Canada, as required by the Canada-Uni ted States Reciprocal Tax Convention [“the 1942 Convention”], for the taxation year ending June 30, 1985.
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