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FCTD

Albert Manley v. Her Majesty the Queen, [1984] CTC 8, 83 DTC 5440

In this case the damages were calculated by reference to two per cent of the purchase price of the Levy shares what Manley would have been paid if the rest of the Levy group had been bound by the transaction between the plaintiff and Ben Levy. ...
FCTD

Morbane Developments LTD v. Minister of National Revenue, [1981] CTC 490, 81 DTC 5362

Its shares were held equally by two groups that of Mr Max Tanenbaum and that of Mr William McLachlan. 2. ...
FCTD

Olympia Interiors Ltd. v. R., [1997] 2 CTC 70

Attached hereto and marked exhibit “C” to this my affidavit are true copies of pgs. 48 & 49 of the examination. 4. ...
FCTD

SMC Pneumatics (Canada) Ltd. v. M.N.R., [1997] 2 CTC 321

(my emphasis) Facts On February 22, 1990, the Secretary of the Machinery & Equipment Advisory Board (MEAB) signed an Application for Duty Remission under the Machinery Program (Application #2037644), submitted by W.C.I. ...
FCTD

Braceland v. Revenue Canada Fairness Group Appeals, [1999] 3 CTC 343, 99 DTC 5189

Beaulac:-Points #1, #2 & #4- These comments all deal with taxation year prior to 1994. ...
FCTD

Hollinger v. M.N.R., 73 D.T.C. 5003, [1972] C.T.C. 592 (FCTD)

If this section were to apply to the present appellant, as suggested by the respondent, she would be paying a tax of close to $70,000 (or $69,860.03) as hereinafter set down instead of an amount of $55,057.12 according to the appellant or $51,067.27 if she was living in the Province of Ontario, as hereunder set down: Federal tax of $16,280.69 Provincial tax of $ 4,225.78 US tax of $30,560.80 $51,067.27 According to the calculations of the appellant, the latter should pay a tax of $55,057.12 on a taxable income of $97,487.47: Federal tax Satin Nil Provincial tax ches cha $24,497.32 US tax $30,560.80 $55,057.12 She would, according to the respondent, on a taxable income of $97,487.47 pay a tax of $69,860.03: Federal tax $14,801.91 Provincial tax $24,497.32 US tax $30,560.80 $69,860.03 Counsel for the appellant says that the latter is not trying to avoid or lessen her tax liabilities on the income she has received. ...
FCTD

Her Majesty the Queen v. National System of Baking of Alberta Limited*, [1978] CTC 30, 78 DTC 6018

The legislation provided that, on the initiation of the taxation of capital gains, the market value of shares quoted on the London Stock Exchange be determined with reference to its market quotations on April 6, 1965, except where in consequence of special circumstances prices so quoted are by themselves not a proper measure of market value.” [1] In November 1964 serious discussions had begun between the chairman of Vickers Ltd and the taxpayer’s father, chairman of R W Crabtree & Sons Ltd contemplating the acquisition of all of the latter company’s issued shares by Vickers Ltd. ...
FCTD

New Continental Oil Company of Canada Limited v. Her Majesty the Queen, [1976] CTC 44, 76 DTC 6038

By a letter (Exhibit P-23), dated December 19, 1947 (! attach no significance to the discrepancy in dates) referring to the transactions previously described, the plaintiff undertook to pay the optionees, personally and not in their capacities as syndicate managers, the sum of $50,000 out of the plaintiff’s 50% share of the net proceeds of production. ...
FCTD

Her Majesty the Queen v. Ball Brothers Limited, [1976] CTC 793, 77 DTC 5004

The passage from which the foregoing statement by Mr Justice Judson is taken, at pages 606-7 [315, 5229], is:.. » The option, in my opinion, is all important. ...
FCTD

MRS Katie Esar and MR Reuben Esar v. Her Majesty the Queen, [1974] CTC 34, 74 DTC 6062

Throughout the years the plaintiffs’ returns were prepared by a firm of Montreal chartered accountants, Messrs Mallette, Cote, Normandin & Company. ...

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