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TCC
Ambroise Dupont v. Minister of National Revenue, [1990] 2 CTC 2071
Ouellette & Brett (supra). Later, he concluded as follows at page 2054 (D.T.C. 354): Accordingly, I find that the point at issue, as in In re Spiral et al. v. ...
FCTD
Royal Trust Company and James J L Franceschini, Executors of the Estate of Myrtle Louise McCreath v. Her Majesty the Queen, [1982] CTC 36, 81 DTC 5338
The transfer of the shares of Mount Royal Paving & Supplies Limited to the trustee was, in my opinion, a colourable gift and not a bona fide disposition of the type which s.5(1) is intended to exempt. ...
SCC
Her Majesty the Queen in the Right of the Province of Manitoba v. Air Canada, [1980] CTC 428
Hays v Pacific Mail SS Co, 17 How 596; St Louis v Ferry Co, 11 Wall 423; Morgan v Parham, 16 Wall 471; cf Ayre & Lord Tie Co v Kentucky, 202 US 409. ...
T Rev B decision
J F Burns, Sr, James F Burns, Jr, Clayton R Carroll, Burnco Industries Limited v. Minister of National Revenue, [1980] CTC 2817, 80 DTC 1705
On September 28, 1973, Underwood McLellan & Associates Ltd wrote Carburn Aggregates, giving their engineering report on existing proposed developments of the Carburn Angus Pit which included the Ogden pit. ...
TCC
Beaudry v. R., [1998] 1 CTC 2042
The difference was explained in the following terms: [TRANSLATION] Q. [...] ...
TCC
216663 Ontario Ltd. v. R., [1998] 3 CTC 2425, 98 DTC 1628
., in conformity with Stubart, was careful to qualify the importance of a bona fide business purpose by stating that, although it "... is not determinative of the artificiality of the deduction”, it “is certainly relevant”. ...
TCC
Pozzebon v. R., [1998] 3 CTC 2902, 98 DTC 1940
. … The words “prevent” and “prévenir” mean the same: to stop an event from happening before it happens. ...
TCC
Grigg v. R., [1998] 4 CTC 2758, 99 DTC 188
Robertson J.A. categorized the reported cases into two categories: those that deal with “inside directors” and those that deal with “outside directors” At page 263 (5416-17), he states: [...] it is difficult to deny that inside directors, meaning those involved in the day-to-day management of the company and who influence the conduct of its business affairs, will have the most difficulty in establishing the due diligence defence. ...
SKCA decision
Her Majesty the Queen, Appeliant, v. George E Paveley, [1976] CTC 477
Lord Denning in Hosegood v Hosegood (1950), 66 TLR 735 at 738, in a civil case, put it this way: When people say that a man must be taken to intend the natural consequences of his acts, they fall Into error: there is no “must” about #; it is only "may”. ...
FCTD
Her Majesty the Queen v. Pollock Sokoloff Holdings Corp, [1974] CTC 391, 74 DTC 6321
Thereafter interest would be an even $5,000 per annum at 10% [1] *. The amount of $7,207.98 written off in 1968 had been set up as an asset and income tax paid on same in 1967 as it was not until 1968 that it was considered to be a bad debt. ...