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SCC

Québec (Communauté urbaine) v. Corp. Notre-Dame de Bon-Secours, 95 DTC 5017, [1994] 3 SCR 3, [1995] 1 CTC 241

At page 87 of his text Construction of Statutes (2nd ed. 1983), Driedger fittingly summarizes the basic principles: "... the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act and the intention of Parliament". ...
FCA

The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065, [1996] 2 CTC 55 (FCA)

.: This is an appeal from a judgment of the Trial Division allowing in part the respondent’s appeal from the reassessment of its income tax for the 1978 taxation year. ...
FCTD

McClain Industries of Canada Inc. v. The Queen, 78 DTC 6356, [1978] CTC 511 (FCTD)

In The Queen v Ken & Ray’s Collins Bay Supermarket Limited, [1975] CTC 504; 75 DTC 5346, Kerr, J decided that a somewhat similar management bonuses arrangement was contingent on the necessary funds being available. ...
TCC

Canwest Broadcasting Ltd. v. The Queen, 96 DTC 1375, [1995] 2 CTC 2780 (TCC)

The appellant produced cases, uncontested by the respondent, which have held interest expense to be deductible where the interest expense exceeds the income from property (Alberta & Southern Gas Co. v. ...
TCC

Husky Oil Ltd. v. The Queen, 95 DTC 316, [1995] 1 CTC 2184 (TCC), aff'd 95 DTC 5244 (FCA)

("Allarco '); and (c) 840 owned all of the issued shares of 348841 Alberta Ltd. ...
FCTD

The Queen v. Jasper, 94 DTC 6519, [1994] 2 CTC 309 (FCTD)

As I see it, the payment toward the mortgage can only be an allowance for maintenance of those for whom maintenance was intended under the agreements that is, the defendant at least initially, and any children living at home after July 1982 pending completion of their education. ...
SCC

Canada v. Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312, [1994] 2 CTC 25

This principle is recognized in Interpretation Bulletin IT-410R, "Debt Obligations —— Accrued Interest on Transfer", which states (in paragraph 3), the amount, if any, of the interest determined for the purpose of subsection 20(14) is unaffected by either the prospects of its payment or non-payment or the nature or value of any consideration given by the transferee". ...
FCA

The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6607, [1990] 2 CTC 448 (FCA)

.: I have had the advantage of reading the reasons for judgment prepared by my brother Urie, J.A. ...
TCC

Wheeliker v. R., 98 DTC 1110, [1998] 1 CTC 2021 (TCC)

These concerns arose from a series of events, including (a) his inability to cause the $20,000 cheque to be sent to Revenue Canada; (b) his failure to supply accurate statements showing the financial condition of the Corporation; (c) the fact that without Board authorization Jardine hired his wife as an employee of the Corporation; (d) his authorization to pay the sum of approximately $10,000 to Green, Haley & Pye for a restructuring report without receiving Board authorization; (e) his alleged verbal abuse of certain production employees of the Corporation; (f) his general habit of running the Corporation, making decisions and enforcing certain procedures without alerting the Board; and (g) his rosy projections of increased numbers of tourist buses and increased sales to customers, including a major customer, Jean Depot, which projections did not materialize. ...
FCA

Prince Rupert Hotel (1957) Ltd. v. The Queen, 95 DTC 5227, [1995] 2 CTC 212 (FCA)

., as he then was, in London & Thames Haven Oil Wharves Ltd. v. Attwool (1966), 43 T.C. 491, at page 515: The question whether a sum of money received by a trader ought to be taken into account in computing the profits of gains arising in any year from his trade is one which ought to be susceptible of solution by applying rational criteria. ...

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