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FCA

Her Majesty the Queen v. Crown Forest Industries Ltd., [1994] 1 CTC 174, 94 DTC 6107

. rent, royalty or similar payment, including, butnotsoasto restrict the generality of the foregoing, any payment.... 3 The parties, through counsel, tendered an agreed statement of facts at trial (Exhibit 1). 4 Paragraph 883(a)(1) reads: (a) Income of foreign corporations from ships and aircraft.— The following items shall not be included in gross income of a foreign corporation, and shall be exempt from taxation under this subtitle: (I) Ships operated by certain foreign corporations.— Gross income derived by a corporation organized in a foreign country from the international operation of a ship or ships if such foreign country grants an equivalent exemption to corporations organized in the United States. 5 This “effective connection” is established by various factors, one of which, admittedly, is Norsk’s place of management. 6 Since this is a determination of foreign law, it is a finding of fact. ...
TCC

Bronson Homes Limited v. Minister of National Revenue, [1993] 2 CTC 2060

This case arises as a result of reassessment of the appellant (” Bronson") by the Minister, notices of reassessment which are dated February 13, 1984. ...
TCC

Burns v. R., [1998] 4 CTC 2149

Stedman’s Medical Dictionary- 25th Edition (Williams & Wilkins) offers this definition: handicap- A physical, mental, or emotional condition that interferes with an individual’s normal functioning. ...
FCA

Ablan Leon (1964) Ltd. v. MNR, 76 DTC 6280, [1976] CTC 506 (FCA)

The separation of legal personality as between one acting in his personal capacity and the same person acting in his capacity qua executor or trustee is as distinct as that of an incorporated company and its chief shareholder: see Salomon v Salomon & Co. ...
TCC

Central Supply Company (1972) Ltd. v. The Queen, 95 DTC 434, [1995] 2 CTC 2320 (TCC)

London & W. Riding Invest. Ltd., [1967] 2 Q.B. 78, [1967] 1 All E.R. 518, at page 802 (D.T.C. 528), where Diplock L.J. said, As regards the contention of the plaintiff that the transactions between himself, Auto-Finance Ltd. and the defendants were a "sham", it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ...
TCC

MacIntyre v. M.N.R., docket 96-223-UI

He now works 40 hours a week under a new owner but in 1993 he was there only “off and on”. [45]Mr. ...

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