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& R. Weir, Limited v. Minister of National Revenue, [1964] CTC 529 DUMOULIN, J. ... " The witness admits these particular operations were not transacted on the open market but through private contracts. ... So far, so good, but, then, whose bonds attracted that ‘ ‘ natural increment”? ...

Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081 CAMERON, J. ... Secondly, a transaction which, on its true construction, is of a kind that would escape tax is not taxable on the ground that the same result could be brought about.by a transaction in another form which would attract tax. ’ ’ The question for determination, therefore, is ‘‘ What is the real character of the receipt?’’ ... C.I.R., 12 T.C. 1955, and similar cases. ’ ’ In the instant case, the appellant company retained the full ownership of its only capital asset—the Barclay Hotel. ...

Attorney General of Canada / Re Claim, under s. 1036 of the Criminal Code, to certain fines, [1937] S.C.R. 403 Supreme Court of Canada Attorney General of Nova Scotia v. ... The matter is now referred to us under section 43 of the Supreme Court Act, in view of the fact that, by section 6 of chapter 226 of the Revised Statutes of Nova Scotia, 1923, the opinion of the Supreme Court of Nova Scotia upon the reference, although advisory only, is, for all purposes of appeal to this Court, to “ be treated as a final judgment of the court between parties.” ... It is contended by the Attorney-General of Canada that they were “ imposed in respect of the breach of any of the revenue laws of Canada,” and that they were “imposed * * * in a proceeding instituted at the instance of the Government of Canada or of a department thereof in which that Government bore the cost of prosecution.” ...

Silver Creek Cedarwood Total CMHC mortgage insurance $ 79,300 $ 66,536 $ 145,836 fee CMHC mortgage application 7,350 7,735 15,085 fee Interest during construction 1,493,823 1,217,282 2,711,105 and lease-up Mortgage guarantee fee 80,291 67,368 147,659 Mortgage brokerage fee 64,233 53,894 118,127 Legal Fees relating to mort 25,000 25,000 50,000 gage financing and other doc umentation Landscaping 100,000 50,000 150,000 Administration and leasing 362,000 243,300 605,300 services Cash flow guarantee 171,525 145,349 316,874 $2,383,522 $1,876,464 $4,259,986 7. ... The Supreme Court of Canada has recently set out the following principles, to be applied on a case-by-case basis, to the computation of profit under ss. 9 & 12 of the Act: Canderel Ltd. v. ... & Minister of National Revenue v. Colford Contracting Co. (1960), 60 D.T.C. 1131 (Can. ...

Unnamed persons Personnes non désignées nommément (2) The Minister shall not impose on any person (in this section referred to as a “third party”) a requirement under subsection 231.2(1) to provide information or any document relating to one or more unnamed persons unless the Minister first obtains the authorization of a judge under subsection 231.2(3). (2) Le ministre ne peut exiger de quiconque — appelé « tiers » au présent article — la fourniture de renseignements ou production de documents prévue au paragraphe (1) concernant une ou plusieurs personnes non désignées nommément, sans y être au préalable autorisé par un juge en vertu du paragraphe (3). ... FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-917-21   STYLE OF CAUSE: AKME POULTRY, BUTTER & EGGS DISTRIBUTORS INC v MINISTER OF PUBLIC SAFETY AND EMERGENCY PREPAREDNESS   PLACE OF HEARING: OTTAWA, ONTARIO   DATE OF HEARING: FEBRUARY 8, 2023   JUDGMENT AND REASONS: PAMEL J.   DATED: october 13, 2023   APPEARANCES: Erin E. Brown Jean-Simon Schoenholz Alexander Carden   For The Applicant Sarom Bahk Jessica Pizzoli For The Respondent SOLICITORS OF RECORD: Norton Rose Fulbright Canada LLP Ottawa, Ontario   For The Applicant Attorney General of Canada Montreal, Quebec   For The Respondent   ...

Cohen and $. J. Cohen were brothers and Leshgold their brother-in-law and that J. ... In support of this contention, the cases on the construction of the words 4 relatives ” or relations ’ ’ in matters involving the interpretation of wills such as Ross v. ... :—There are here two appeals, one by Army & Navy Department Store Limited, an Alberta company (hereinafter referred to as the Alberta Corporation) and the Army & Navy Dept. ...

Oil & Rubber Specialties Inc. v. M.N.R., docket 1999-272-CPP Date: 19990803 Docket: 1999-272-CPP BETWEEN: OIL & RUBBER SPECIALTIES INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and LOUISE RICHARD, Intervenor. ... (iii) ownership of tools – what was provided to the Worker to perform his/her work, if anything? ... The test is conclusive – all the evidence must be examined and the tests applied in order to determine the totality of the relationship at issue. ...

John Crosier, Lucille E Crosier, Albin Trella, Elizabeth Trella, Victor Prousky, Morris Prousky, 233482 Investments Limited, T Caravaggio & Son Limited, Manfred Feldt, Jean Mary Haschyc, Mendel Goldstein, Harry Teperman, David Irving Teperman, Burstein Bag Limited, Burstein Bag Limited v. ... The following schedule sets out the basic particulars of the property interest of the appellants: Property Year Appellants Appellants Karopa Hilltown 1974 John Crosier X 1974 Lucille E Crosier X 1974 Albin Trella X 1974 Elizabeth Trella X 1974 Victor Prousky X 1974 Morris Prousky X 1975 233482 Investments Limited X 1975 T Caravaggio & Son Limited X 1974 Manfred Feldt X 1974 Jean Mary Haschyc X 1974 Mendel Goldstein X 1974 Harry Teperman X 1974 David Irving Teperman X 1974 Burstein Bag Limited X 1975 Burstein Bag Limited X The following information directly relevant to the appellant Burstein is common to all appellants with respect to either one or the other parcel of real estate as indicated above: —The appellant held interest in two joint ventures known as Hilltown Developments Ltd (“Hilltown”) and Karopa Enterprises Ltd (“Karopa”); —The subject assets of these joint ventures were two pieces of raw land abutting each other in the Town of Oakville near the border line with the City of Mississauga; —The original participants and their respective percentage interests of Karopa were as follows: —Shortly after the purchase of the Karopa Property, Doug Roher and Lou Sherriff, the beneficial owners of K Roher Construction Limited and Lyrad Construction Limited respectively, which corporations in partnership owned Briar Developments, declared personal bankruptcy and thereafter Briar Developments ceased its participation in Karopa; Briar Developments (Roher & Sherriff) 29.7% Burstein Bag Limited 26.9% Crosier 1.4% Goldstein 1.7% McGuigan & Feldt 5.2% Prousky (Victor & Morris) 2.3% Trella (Elizabeth & Albin) 5.9% Warwick 11.2% Welta Wool.2% Feldstein 5% Flishlek.3% Rotsteins.3% Steiglan 6.6% Tomco 1.0% 233482 Investments Limited 7.7% 100.0% UUIJ I, IvVV, (“Karopa”) for $832,742.00 satisfied as follows: Cash $245,207.97 29.4% 1st Mortgage 301,867.03 36.2% 2nd Mortgage 50,750.00 6.1 % 3rd Mortgage 234,492.00 28.2% Taxes, etc 425.00.1 % $832,742.00 100.0% — During 1972, other participants of Karopa also encountered financial difficulties, and a reorganization occurred with the remaining participants taking over the vacated syndicate participation, the result being that the eventual composition of the Karopa joint venture was as follows: Burstein Bag Limited 35.720% T Caravaggio & Son Ltd 17.860% 233482 Investments Ltd 10.716% Jean Haschyc 5.706% Elizabeth Trella 5.706% Albin Trella 3.224% Joseph Rajca Jr 3.224% Mendel Goldstein 3.572% Manfred Feldt 3.572% Prousky (Victor & Morris) 3.556% John Crosier (husband & 1.786% Lucille Crosier wife) 1.786% Dorothy McGuigan 1.786% Beverly Young 1.786% 100.000 % Limited for a consideration of $1,901,664, realizing a gross profit of $1,068,922. ... No commission was paid by the group on the sale of the property. — In light of the whole history of the property, the amount received by the appellant as proceeds of disposition of its interest in that property was a Capital receipt. — In any event, the gain attributable to the portion of the appellant’s interest in the property that was acquired when Briar withdrew from the group was a Capital gain in that the appellant was forced to acquire that interest in order to protect its investment in the property. ...

William $. Walker, [1951] CTC 334 HYNDMAN, D.J.:—These two appeals were heard together. ... Mallandaine, (1887) 18 Q.B.D. 276 at 277, Lord Denman said: "The words in 5 & 6 Vict. c. 35, s. 100, Sched. ... It will be noted that Lord Denman says ‘‘ ‘vocation’ is analogous to ‘calling.’ ”’ Other decisions which might be referred to are found in Gordon’s Digest, e.g., Trautwein v. ...

La Ronge Lumber & Electric LTD v. Minister of National Revenue, [1985] 2 CTC 2271, 85 DTC 573 Sarchuk, TCJ:—The appeal of La Ronge Lumber & Electric Ltd (La Ronge) relates to an assessment by the Minister of National Revenue of penalty and interest on the appellant’s income tax liability for its 1981 taxation year. ... Mr Garrison responded by letter dated November 18, 1981 in the following words: We have completed the necessary arrangement with the Bank of Montreal, La Ronge, for Guarantees as follows: Edwin Elton Tubman — $21,874.22 La Ronge Lumber & Electric Ltd. — 16,466.76 The latter amount is $7,000.00 more than required. ... It is well settled law that “... When a debtor is making a payment to his creditor he may appropriate the money as he pleases, and the creditor must apply it accordingly. ...