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FCA

Louis Vaillancourt v. Her Majesty the Queen and Canada Mortgage and Housing Corporation, [1991] 2 CTC 42

Marsh & McLennan, Ltd., [1984] F.C. 609; [1983] C.T.C. 231; 83 D.T.C. 5180 at 244 (D.T.C. 5191; F.C. 627), Clément, D.J.; Golden v. ...
TCC

Chignecto Holdings Limited and Case Realty Limited v. Minister of National Revenue, [1991] 2 CTC 2764, 91 DTC 1354

.: It was agreed at the commencement of the hearing that these cases would proceed on common evidence. ...
TCC

Ambroise Dupont v. Minister of National Revenue, [1990] 2 CTC 2071

Ouellette & Brett (supra). Later, he concluded as follows at page 2054 (D.T.C. 354): Accordingly, I find that the point at issue, as in In re Spiral et al. v. ...
FCTD

Royal Trust Company and James J L Franceschini, Executors of the Estate of Myrtle Louise McCreath v. Her Majesty the Queen, [1982] CTC 36, 81 DTC 5338

The transfer of the shares of Mount Royal Paving & Supplies Limited to the trustee was, in my opinion, a colourable gift and not a bona fide disposition of the type which s.5(1) is intended to exempt. ...
SCC

Her Majesty the Queen in the Right of the Province of Manitoba v. Air Canada, [1980] CTC 428

Hays v Pacific Mail SS Co, 17 How 596; St Louis v Ferry Co, 11 Wall 423; Morgan v Parham, 16 Wall 471; cf Ayre & Lord Tie Co v Kentucky, 202 US 409. ...
T Rev B decision

J F Burns, Sr, James F Burns, Jr, Clayton R Carroll, Burnco Industries Limited v. Minister of National Revenue, [1980] CTC 2817, 80 DTC 1705

On September 28, 1973, Underwood McLellan & Associates Ltd wrote Carburn Aggregates, giving their engineering report on existing proposed developments of the Carburn Angus Pit which included the Ogden pit. ...
TCC

Beaudry v. R., [1998] 1 CTC 2042

The difference was explained in the following terms: [TRANSLATION] Q. [...] ...
TCC

216663 Ontario Ltd. v. R., [1998] 3 CTC 2425, 98 DTC 1628

., in conformity with Stubart, was careful to qualify the importance of a bona fide business purpose by stating that, although it "... is not determinative of the artificiality of the deduction”, it “is certainly relevant”. ...
TCC

Pozzebon v. R., [1998] 3 CTC 2902, 98 DTC 1940

. The words “prevent” and “prévenir” mean the same: to stop an event from happening before it happens. ...
TCC

Grigg v. R., [1998] 4 CTC 2758, 99 DTC 188

Robertson J.A. categorized the reported cases into two categories: those that deal with “inside directors” and those that deal with “outside directors” At page 263 (5416-17), he states: [...] it is difficult to deny that inside directors, meaning those involved in the day-to-day management of the company and who influence the conduct of its business affairs, will have the most difficulty in establishing the due diligence defence. ...

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