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INTRODUCTION [1]         The plaintiff Giesecke & Devrient Security Card Systems, Inc. ... " [29]       In Canada (Minister of Natural Revenue- Customs & Excise) v. ... Morris Rosenberg Deputy Attorney General of Canada                                    FOR DEFENDANT      [1]       The definition of manufacture in [1968] S.C.R. 140 "> The Queen v. ...

R & S Industries Inc. v. The Queen, 2017 TCC 75 Docket: 2014-3997(IT)G BETWEEN: R & S INDUSTRIES INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.     ... Costs of the motion shall be in the cause.   The Respondent shall file a reply on or before June 30, 2017.   ... Graham” Graham J.   Citation: 2017 TCC 75 Date: 20170505 Docket: 2014-3997(IT)G BETWEEN: R & S INDUSTRIES INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ...

That where any stockbroker, acting either as principal or agent, effects the sale of a taxable security by means of a transaction which is not executed on a stock exchange in Canada, the tax exigible on the transaction is to be paid to the Crown by the vendor stockbroker affixing excise tax stamps of the requisite value to the duplicate of the memorandum of sale retained on file in his office. ‘ ‘ (12. ... These regulations were subsequently rescinded with effect from 1st June, 1937, by the order of the Governor-in-Couneil and the following regulations substituted therefor:— " " 2. ... Thus I must conclude that since by statute, sec. 60, the duty is payable by the vendor of the " " security ’ ’ in excise stamps, it must be assumed that the stamps were purchased by the defendants as voluntary agents of the vendors and thus that the stamps originally came into possession of the defendants as agents of the vendors of the securities. ...

At page 618, I observed, * * * Leprohon v. The City of Ottawa [9] * * * was decided in 1877. ... It would seem that the tax is “the exaction * * * of a percentage duty on services” of which Lord Cave said that it “would ordinarily be regarded” and should be classified “as indirect taxation”— City of Halifax v. ... Attorney-General for Canada [55], where Lord Haldane said: * * * If the statute is ultra vires as regards the first class of cases, it has to be pronounced to be ultra vires altogether. ...

Otte   (To be determined)     (To be determined)       (18,315.68) Less consideration paid by Mr. & Mrs. Otte in respect of the OAC Items       (437,331.66) Benefit amount for the purposes of subsection 173(1) of the ETA   To be determined V. ... Clayards   Firm: Kanuka Thuringer LLP For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           Excise Tax Act, R.S.C. 1985, c. ...

Rolls Wood Group (Repairs & Overhauls) Ltd. v. Canada (Minister of National Revenue), docket T-941-99 Date: 20010111 Docket: T-941-99                      BETWEEN:      ROLLS WOOD GROUP (REPAIRS & OVERHAULS) LTD.      ... Facts [2]      The applicant, Rolls Wood Group (Repairs & Overhauls) Ltd. ... [emphasis added]      (6) Section 59      Officers who may redetermine the tariff classification or reappraise the value for duty of imported goods under section 60 of section 61 of the Act.     ...      ...

He adds:— " " It is impossible, I think, to treat the decision of the House of Lords as laying down that capital, which is used as circulating capital, is not capital within the meaning of Sub-rule (f). ... The Montreal Light, Heat & Power company estimates that annual sum in its own case at $303,119.18. ... The words " 4 the income” must, I think, mean the assessable income of the taxation period. ...

Deloitte & Touche v. Livent Inc. (Receiver of), 2017 SCC 63, [2017] 2 S.C.R. 855       SUPREME COURT OF CANADA   Citation: Deloitte & Touche v. ... (Receiver of), 2017 SCC 63 Appeal Heard: February 15, 2017 Judgment Rendered: December 20, 2017 Docket: 36875   Between:   Deloitte & Touche (now continued as Deloitte LLP) Appellant   and   Livent Inc., through its special receiver and manager Roman Doroniuk Respondent  - and-   Canadian Coalition for Good Governance and Chartered  Professional Accountants of Canada Interveners         Coram: McLachlin C.J. and Karakatsanis, Wagner, Gascon, Côté, Brown and Rowe JJ.   ... (Wagner and Côté JJ. concurring)     Note: This document is subject to editorial revision before its reproduction in final form in the Canada Supreme Court Reports.       ...

McTaggart, Hannaford, Birks & Gordon Limited v. Minister of National Revenue, [1952] CTC 385, 52 DTC 1218 THORSON, P. ... He contended that the omission of the words made no change in the law and that the ‘ ‘ losses ’ ’ that were deductible under Section 5(p), as it stood after the deletion of the words, were business operation losses just as they had been previously. ... In view of the wording of section 3(1) of the Act which provides among other things, that ‘ "income'"... includes... dividends...’, it is impossible for me to accept this proposal. ’ ’ The Board dealt with the matter again in Smith, Davidson and Wright Limited v. ...

The Queen, [1984] C.T.C. 284; 84 D.T.C. 6276 — April 10, 1984 — (F.C.A.) — Taxpayer Successful; Stubart Investments Limited v. ... The Queen, [1985] 2 C.T.C. 79; 85 D.T.C. 5310 — June 2, 1985 — (F.C.A.) — Taxpayer Successful; BXL Bulk Explosives Limited v. M.N.R., [1985] 2 C.T.C. 2256; 85 D.T.C. 579 — August 29, 1985 — (T.C.C.) — Taxpayer Successful. ...