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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   ...

SARJI Plaintiff- and- MINISTER OF NATIONAL REVENUE (Customs & Excise) Defendant REASONS FOR ORDER INTRODUCTION LEMIEUX J.: (1]        Ahmad A. ... She was wearing several pieces of jewellery.          They were visible.    ... THE MINISTER OF NATIONAL REVENUE (CUSTOMS & EXCISE) PLACE OF HEARING:                MONTRÉAL, QUÉBEC DATE OF HEARING:                   MARCH 16, 1999 REASONS FOR JUDGMENT OF THE HONOURABLE MR. ...

Plaintiff / Defendant by Counterclaim and AP&C ADVANCED POWDERS & COATINGS INC. ... “Nicholas McHaffie” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-126-19   STYLE OF CAUSE: TEKNA PLASMA SYSTEMS INC v AP&C ADVANCED POWDERS & COATINGS INC   PLACE OF HEARING: HEARD IN WRITING   ORDER AND REASONS: MCHAFFIE J.   DATED: December 5, 2024   WRITTEN REPRESENTATIONS BY: François Guay Jean-Sébastien Dupont Audrey Berteau   FOR THE PLAINTIFF/DEFENDANT BY COUNTERCLAIM Andrew Brodkin Ben Hackett   FOR THE DEFENDANT/PLAINTIFF BY COUNTERCLAIM SOLICITORS OF RECORD: SMART & BIGGAR LLP Montreal, Quebec   FOR THE PLAINTIFF/DEFENDANT BY COUNTERCLAIM GOODMANS LLP Toronto, Ontario FOR THE DEFENDANT/PLAINTIFF BY COUNTERCLAIM   ...

Queen & Metcalfe Carpark Ltd. v. MNR, 74 DTC 6007, [1973] CTC 810 (FCTD), aff'd [1976] CTC xvi (FCA) Sweet, D.J. ... November 6, 1967 $2,182.57 December 30, 1967 $4,164.94 December 15, 1967 $ 279.98 February 9, 1968 $2,019.32 March 11, 1968 $ 320.03 April 11, 1968 $ 79.60 May 14, 1968 $ 12.03 May 31, 1968 $ 12.35 August 31, 1968 $ 4.15 Smith, Winston, Wolman, Roth & Smith November 7, 1967 $500.00 This is a firm of chartered accountants. ... A H Fitzsimmons & Co Limited December 22, 1967 $1,025.30 March 30, 1968 $1,307.17 Mr. ...

Canadian Propane Gas & Oil Ltd. v. MNR, 73 DTC 5019, [1972] CTC 566 (FCTD) Cattanach, J:—These are appeals from the assessment of the appellant to income tax for its 1966 and 1967 taxation years by the Minister. ... Subsequently the corporate name was changed to Canadian Propane Gas & Oil Limited. ... In assessing the appellant as he did the Minister invoked the provisions of paragraph 20(6)(g) of the Income Tax Act and accordingly reduced the capital cost of the Class 8 and Class 10 depreciable assets as follows: Class 8 Class 10 Total Zenith Purchase price $161,000.00 $136,000.00 $297,000.00 Allowed by Minister 55,685.00 53,742.00 109,427.00 Reduction $105,315.00 $ 82,258.00 $187,573.00 Burro Purchase price $242,685.00 $246,150.00 $488,835.00 Allowed by Minister 65,726.00 78,337.00 144,063.00 Reduction $176,959.00 $167,813.00 $344,772.00 Grover’s Purchase price $145,530.00 $ 41,532.00 $187,062.00 Allowed by Minister 62,750.00 30,532.00 93,282.00 Reduction $ 82,780.00 $ 11,000.00 $ 93,780.00 In determining the amounts that the Minister allowed as being reasonably regarded as being in part the consideration for the depreciable property within Classes 8 and 10, the Minister considered each item within those classes as outlined in Schedules A, B and C to his Reply to the Notice of Appeal. ...

B & J Music Limited v. Her Majesty the Queen, [1981] CTC 315 Gibson, J:—B & J Music Limited (formerly Buegeleisen & Jacobson Limited) until 24 June 1974 was controlled by non-residents of Canada namely by residents of the United States. ... B & J Music Limited appeals from assessments for tax in those years in this action. ... In my view, section 125 of the Income Tax Act is a special section affording a “Canadian-controlled private corporation” special tax treatment and it does not in any of its provisions refer to any other corporations; and further Parliament did not legislate in this section to deny the so-called small business deduction to any corporation such as B & J Music Limited which was not in 1971 a “Canadian-controlled private corporation". ...

They may be summarized as follows: — between March 24, 1992 and February 1, 1993, the respondent imported air diffusers into Canada; — the imported air diffusers were made of plastic and were designed as an attachment to hair dryers; — at the time of each importation, the air diffusers were classified under Tariff item No. 3926.90.90 of Schedule I to the Customs Tariff [3] as “other articles of plastics”; — the respondent urged that the air diffusers should be classified under Tariff item No. 8516.31.10 as parts of domestic hair dryers and therefore requested, pursuant to paragraph 60(l)(b) of the Customs Act, a re-determination of the tariff classification of the air diffusers. It was determined that the imported goods were properly classified under Tariff item No. 3926.90.90 as other articles of plastics; — the respondent subsequently requested a further re-determination of the tariff classification of the air diffusers by the Deputy Minister of National Revenue for Customs and Excise pursuant to paragraph 63(l)(a) of the Customs Act; — on August 26, 1993, the appellant confirmed the classification of the air diffusers under Tariff item No. 3926.90.90; — on September 15, 1993, the respondent appealed the decision to the Tribunal pursuant to section 67 of the Customs Act; — by the decision here under appeal, the Tribunal found in favour of the respondent; — the parties are in agreement that the classification of goods under Schedule I to the Customs Tariff is to be governed by the Generpal Rules for the Interpretation of the Harmonized System and the Canadian Rules and the Explanatory Notes to the Harmonized Commodity Description and Coding System. ... Deputy Minister of National Revenue (Customs & Excise) [7] ', a classification matter before the Tribunal dealing with television converters, the Tribunal, in concluding that television converters were parts to television receivers, wrote: Although the television can operate without a converter by increasing the number of channels a television is capable of receiving, a converter contributes directly to the main function of a television receiver, that being the reception of audio-visual signals. ...

H a Fawcett & Son, Limited v. Her Majesty the Queen, [1979] CTC 303, 79 DTC 5224 Dubé, J:—The main issue to be determined in this case is whether the plaintiff corporation in its fiscal year ending November 30, 1975 was associated with Fawcett Enterprises Limited and Son Valley Ranch Limited under paragraph 256(1)(b) of the Income Tax Act on the basis that all three corporations are controlled by the same person, George C Fawcett. ... If it had been the intention of Parliament to exclude from the provisions of paragraph 256(1)(b) shares which were acquired by an executor or a trustee by virtue of the death of any other person it would have done so in clear unambiguous terms, as it did for the purposes of other subsections.* [5] The appeal therefore should be dismissed with costs. 1 Judson, J in MNR v Consolidated Holding Co, [1974] S.C.R. 419 at 423; [1972] CTC 18 at 20; 72 DTC 6007 at 6008. 2 T Thurlow, J (now ACJ) in Career Girl Store v MNR, [1967] 1 Ex CR 21; [1966] CTC 330; 66 DTC 5244. 3 + Vineland Quarries & Crushed Stone v MNR, [1966] Ex CR 417, 429; [1966] CTC 69; 66 DTC 5092. The reasons and conclusions of Cattanach, J were adopted by the SCC—see 67 DTC 5283 at 5284. 4 § Buckerfield’s Limited v MNR, [1965] 1 Ex CR 299, at 305; [1964] CTC 504 at 509; 64 DTC 5301 at 5304. 5 See subparagraph 256(7)(a)(ii) added by SC 1977-78 c 1, section 99, which reads (7) Where control deemed not to have been acquired. ...

Her Majesty the Queen, Creditor — v. Harold Wayne Mullins, [1985] 2 CTC 128 Le juge Denault:—Le 18 décembre 1984, le juge Rouleau a accordé une requête pour ordonnance provisoire de constitution de charge immobilière, en vertu de la Règle 2400 des Règles de la Cour fédérale dans les termes suivants: IT IS ORDERED that unless sufficient cause to the contrary be shown before the Court, sitting in Montreal at 1 Notre-Dame Street East on the 25th day of January, 1985 at 10:00 am, that a one half undivided interest in the undivided half (or a one quarter undivided interest) of the said immoveable shall stand charged with the payment of $17,583.56 remaining due on said certificate as well as the supplementary interest at the annual rate provided for time to time by section 161(1) of the Income Tax Act on the sum of $10,307.60 as of the 2nd day of August 1984 until the date of complete payment together with the costs of this application and it is further ordered that said charge subsists until the hearing of aforesaid reasons. ... Le juge Marceau, dans l'affaire Couillard * [1] s'exprimait ainsi dans une affaire semblable: Il ne s’agit pas ici d’une saisie-exécution immobilière, mais l’ordonnance de constitution de charge recherchée aura une portée plus grande que n’en a l’enregistrement d’une hypothèque judiciaire comme le prévoit le Code civil de la province de Québec (art 2034 et s et art 2121 cc). ... Ainsi donc, en se prévalant de la Règle 2400, la créancière ne procède pas immédiatement à la saisie de l'immeuble — elle pourra le faire éventuellement — mais elle veut le grever de l'équivalent d'une hypothèque judiciaire pour assurer la protection de ses droits. ...