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TCC
Alexander Orr v. Minister of National Revenue, [1989] 2 CTC 2348, 89 DTC 557
You are willing to gift approximately $100,000 worth of shares (after a proposed split — see below) in the company to Lance and Kevin in order to obtain maximum tax benefits on a total family unit basis.  ...
TCC
Pedro Cabezuelo v. Minister of National Revenue, [1983] CTC 2775, 83 DTC 679
Apart altogether from what has been said concerning the existence of a trust, if superior judicial authority did not cling so tenaciously to the doctrine of the absolute distinction of identity between a corporation and its shareholders as propounded over 85 years ago by the House of Lords in Salomon v Salomon & Co Ltd, [1897] AC 22, one might regard a single shareholder corporation like Enterprises in the light of its relationship to the appellant and conclude that in truth and substance what was attempted was to establish a trust under which the settlor, the trustee and the sole beneficiary are the same person, which is not permissible under the law of trusts.  ...
TCC
Walters v. R.|, [1999] 1 CTC 2211, 99 DTC 363
Exhibit A-l contained a number of documents relative to the operation in question and Exhibit A-2 was a summary of the profit and loss situation for M & K Stables from 1975 to 1992.  ...
TCC
Brad and Luisa Stevenson v. Her Majesty the Queen, [1997] 1 CTC 2236 (Informal Procedure)
.: — It was agreed at the commencement of the trial that the evidence given in one would be considered in the other, where applicable.  ...
TCC
Landry v. The Queen, docket 96-4196-IT-G
The money went into her account, then she made a cheque out to L & H Construction Steelworks Ltd.  ... This was signed by L & H Construction Steelworks Ltd. and purported to convey any assets of the Company to Claire Jeanne d'Arc Landry and Leonard Michel Landry.  ...
TCC
Fording Coal Limited v. Her Majesty the Queen, [1995] 1 CTC 2734
(See Maritime Telegraph & Telephone Co. v. The Queen, [1992] 1 C.T.C. 264, 92 D.T.C. 6191 (F.C.A.), Anderson v.  ... Britannica World Language Dictionary, Funk & Wagnail's New Standard Dictionary of the English Language, The Random House Dictionary of the English Language, The Living Webster Dictionary and Thorndike-Barnhard (American dictionary).  ...
TCC
Bohdan Barabash and Wolodymyr Barabash v. Minister of National Revenue, [1993] 2 CTC 3080, 93 DTC 1436
That would have been Field & Field, apparently. Definitely not, she said.  ... She confirmed that her telephone call to Field & Field was April, May, June, 1985.  ...
TCC
Collins v. R., [1998] 3 CTC 2980
. +. An appropriately qualified person must certify the mental or physical handicap is the reason the patient requires that the school specially provide the equipment, facilities or personnel for the care or the care and training of individuals suffering from the same handicap.  ... 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.  ...
TCC
Burns v. The Queen, 94 DTC 1370, [1994] 1 CTC 2364 (TCC)
At page 318 (D.T.C. 6164) of his judgment, Décary, J. stated: The question is whether the debts at issue were in fact acquired "... for the purpose of gaining or producing income from a business or property....”  ...
TCC
Byrt v. MNR, 91 DTC 923, [1991] 2 CTC 2174 (TCC)
Fetterly of Calgary, "decided to do something" to protect their interests and engaged the Regina law firm of MacPher- son, Leslie & Tyerman.  ...