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TCC
Peter K. Wu v. Her Majesty the Queen, [1996] 3 CTC 2879 (Informal Procedure)
.: — This appeal was heard under the Informal Procedure of this Court. ...
TCC
Rossi v. R., [1997] 2 CTC 2033
Canada) [1995] 2 C.T.C. 2979 (D), 96 D.T.C. 1806 at page D.T.C. 1807 at the Tax Court level of the appeal: [...] ...
TCC
Shell Canada Ltd. v. R., [1997] 2 CTC 2352, 97 DTC 257
It reads: TAKE NOTICE that an application will be made by teleconference at a date and time to be determined by the Court for an Order pursuant to paragraph 108(1 XJ) [1] of the Tax Court of Canada Rules- General Procedure (‘Rules’) for the following relief: THE MOTION IS FOR: (a) an order pursuant to section 88(c) of the Rules requiring the production of documents described as ‘21(l)(b) documents’ in the attached affidavit which the Respondent has improperly claimed to be privileged and documents described as ‘ 13(1)(Z?) ...
TCC
Hudson Bay Mining and Smelting Co. v. R., [1997] 2 CTC 2419, 96 DTC 1246
Thomas Summerson & Sons Ltd., [1926] 1 K.B. 131, the vendor sold a security with interest rights during the currency of an interest period. ...
TCC
Emmerson v. R., [1998] 1 CTC 2182
The French wording states that normalized pension is the amount that would be payable “si les hypothèses suivantes étaient admises” (= if the following hypotheses are “admitted”). ...
TCC
Glass v. R., [1998] 1 CTC 2190, 98 DTC 1085
The liability of every director, officer, liquidator and member of a company that is struck off the register,... pursuant to section 280, 281, 283 or 344, shall continue and may be enforced as if the company had not been struck off the register. 286.(1) Where a company has been dissolved, … under this Act or any former Companies Act, the court may, if it is satisfied that it is just that the company... be restored to the register, not more than 10 years after the date of the dissolution or cancellation, on application by the liquidator, a member, a creditor of the company..., or any other interested person, make an order, subject to the conditions and on the terms the court considers appropriate, restoring the company... to the register. (2) Where a company or... is restored to the register under subsection (1), the company shall be deemed to have continued in existence,... and proceedings may be taken as might have been taken if the company had not been dissolved,... (3) The court may make an order pursuant to subsection (1) restoring a company... to the register for a limited period, and, after the expiration of that period, the company shall promptly be struck off the register,... 287. ...
TCC
Lomas v. R., [1998] 1 CTC 2462
At page 6013, Linden J.A. stated: …] otherwise agree that the Moldowan test should be applied sparingly where a taxpayer’s ‘business judgment’ is involved, where no personal element is in evidence, and where the extent of the deductions claimed are not on their face questionable. ...
TCC
Nagasaka v. R., [1998] 1 CTC 3047
. /?. [4] For the purpose of computing her income under section 3 of the Income Tax Act, a taxpayer is entitled to deduct losses which derive from a business or property which is a source of income; in order for a business or property to be a source of income it must either produce a profit, or at least the taxpayer must have a reasonable expectation of profit from it. ...
TCC
Makowetski v. R., [1998] 3 CTC 2271
Appellant’s counsel referred to Courtney & Fairbairn Ltd. v. Tolaini Brothers (Hotels) Ltd., [1975] 1 All E.R. 716 (Eng. ...
TCC
McRae v. R., [1998] 3 CTC 2283
. /?., [1992] 1 S.C.R. 877 (S.C.C.) the Supreme Court of Canada had occasion to consider the situs of unemployment insurance benefits for purposes of the section 87 exemption. ...