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M.N.R. v. Bethlehem Copper Corp. Ltd., [1975] 2 SCR 790

Moreover, in the latter case, Pigeon J. said at page 882: “Mining itself is complete by the production and hoisting of the ore …” In my view, “operation of a mine” in section 83(5) refers only to the extraction of ore from an ore body and does not include processing of the ore after it had been produced. ... Support for this contention is sought in the circumstances that if “mine” has the first of the two suggested meanings, then, (i) the phrase “certified to have been operating on mineral deposits” is inapt as it presupposes an entity capable of carrying on operations; and (ii) the draftsman should have substituted for the clause “that came into production” the clause “that was brought into production”. ... Solicitors for the respondent: Lawrence & Shaw, Vancouver.   [1] [1973] F.C. 565. [2] [1958] S.C.R. 597. [3] [1970] S.C.R. 877. ...
SCC

Ikea Ltd. v. Canada, 98 DTC 6092, [1998] 1 S.C.R. 196, [1998] 2 C.T.C. 61

., relying on London & Thames Haven Oil Wharves Ltd. v. Attwooll (Inspector of Taxes) (1966), [1967] 2 All E.R. 124 (Eng. ... In Saint John Dry Dock & Shipbuilding Co. v. Minister of National Revenue, [1944] Ex. ... After a review of the relevant case law, including Charles Brown & Co. v. ...
SCC

Thorson v. Attorney General of Canada, [1975] 1 SCR 138

Williamson & Sons Ltd., [1896] 2 Q.B. 353; Boyce v. Paddington Borough Council, [1903] 1 Ch. 109; Electrical Development Co. of Ontario v. ... Williamson & Sons Ltd. [16]; Boyce v. Paddington Borough Council [17]. ...   [1] [1972] 2 O.R. 340. [2] [1972] 1 O.R. 86. [3] [1972] 2 O.R. 340. [4] [1924] S.C.R. 331. [5] [1911] 1 K.B. 410, and [1912] 1 Ch. 158. [6] [1911] 1 K.B. 410. [7] (1908), 39 S.C.R. 657. [8] (1853), 4 Gr. 170. [9] (1907), 39 S.C.R. 657. [10] [1924] S.C.R. 331. [11] [1911] 1 K.B.410. [12] [1912] 1 Ch. 158. [13] [1973] 1 All E.R.689. [14] [1902] A.C. 165. [15] (1887), 36 Ch. 593. [16] [1896] 2 Q.B. 353. [17] [1903] 1 Ch. 109. [18] [1919] A.C. 687. [19] [1962] S.C.R. 642. [20] (1946), 71 C.L.R.237. [21] (1923), 262 U.S. 447. [22] (1972), 5 N.B.R. (2d) 653. [23] (1907), 39 S.C.R. 657. [24] (1853), 4 Gr. 170. [25] (1853), 4 Gr. 489 aff’d. (1856), 6 Gr. 1 aff’d (1858), 11 Moo. ...
SCC

Canderel Ltd. v. Canada, 98 DTC 6100, [1998] 1 S.C.R. 147, [1998] 2 C.T.C. 35

He found support for this position in the Court's decision in West Kootenay Power & Light Co. v. ... She found at p. 244 that the trial judge erred in applying to the case at bar the interpretation in Symes of Wilson J.'s rejection in Mattabi Mines, supra, of “both the need for a causal connection between a particular expenditure and a particular receipt, and the suggestion that a receipt must arise in the same year as an expenditure is incurred,” as Symes was not concerned with the timing of a deduction, which was the only issue in the case at bar. 23 Desjardins J.A. turned next to the cases relied upon by the Minister in support of the proposition that where there are two methods acceptable both under G.A.A.P. and for tax purposes, the court will prefer the one that results in a “truer picture” of the taxpayer's profit, including West Kootenay, supra, Maritime Telegraph & Telephone Co. v. ... Gardner Mountain & D'Ambrumenil Ltd. (1947), 29 T.C. 69 (U.K. ...
SCC

Beament et al. v. Minister of National Revenue, 70 DTC 6130, [1970] CTC 193, [1970] SCR 680

. $ 8,725.98 Par value of 2,000 Class B shares......................................................................... $ 2,000.00   $10,725.98 In accordance with the letters patent, the remaining net assets were distributed to the Class A shareholders, Mrs.  ... In the course of his reasons the learned President said: No attack has been made on the bona fide of the arrangements. ... Solicitors for the appellants: Beament, Fyfe, Ault, Hutton & Wilson, Ottawa. ...
SCC

Royal Bank of Canada v. Deputy Minister of National Revenue for Customs and Excise, 81 DTC 5301, [1982] CTC 183, [1981] 2 SCR 139

Solicitors for the appellant: Tory, Tory, Deslauriers & Binnington, Toronto. ...   [1] (1979), 33 N.R. 431. [2] [1968] S.C.R. 140. [3] [1930] S.C.R. 174. ...
SCC

Minister for Mines (Ontario) v. Rio Algom Mines Ltd., [1969] SCR 880

The ore came out of the mine in chunks of 6″ to 8″ in diameter, and proceeded to the mill and concentrating unit, in which it was first crushed to pieces about ¾″ in diameter, and then was subjected to a chemical process which resulted in the chemical extraction of uranium concentrate. ... Solicitors for the appellant: Arnup, Foulds, Weir, Boeckh, Morris & Robinson, Toronto. Solicitors for the respondent: McCarthy & McCarthy, Toronto. ...
SCC

Doyle v. Minister of National Revenue, [1978] 2 SCR 837

Solicitors for the appellant: Gowling & Henderson, Ottawa. Solicitor for the respondent: Roger Tassé, Ottawa.   ...
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Doyle v. Minister of National Revenue, [1978] 1 SCR 547

Solicitors for the appellant: Gowling & Henderson, Ottawa. Solicitor for the respondent: D.S. ...   [1] [1970] C.T.C. 365, 70 D.T.C. 6251, 6262. [2] [1967] Tax A.B.C. 563. ...
SCC

Cam Gard Supply Ltd. v. Minister of National Revenue, [1977] 2 SCR 522

Solicitors for the appellant: Pitblado & Hoskin, Winnipeg. Solicitor for respondent: D.S. ...   [1] [1974] 2 F.C. 236. ...

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