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LEBLANC J.A.   Date: 20210721 Docket: A-224-19 Citation: 2021 FCA 146 CORAM: WEBB J.A. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-224-19   STYLE OF CAUSE: TOMORROW’S CHAMPIONS FOUNDATION v. ... Drouin Deputy Attorney General of Canada For The Respondent   ...

The Purchaser shall, subject to the terms and conditions hereinafter set out, have the right to exercise the option hereby granted to him up to a maximum aggregate — 3,000 — shares during each of the first five years following the date hereof, provided that if the Purchaser shall fail to exercise his option up to such maximum aggregate in any year he shall have the right to exercise the option, in respect of the shares which he failed to exercise his option as aforesaid, at any time during the period of five years after the date hereof. 4. ... The Purchaser hereby acknowledges and agrees that the option to purchase — 13,850 — granted by the Company to the Purchaser under agreement dated January 2, 1974, as a result of a stock option plan established by the Company on November 8, 1973, shall, upon execution of this agreement by the Company and the Purchaser, be null and void and of no effect. ... As this appeal and the appeal in appeal No A-758-81, Anthony K Stephens v The Queen, were argued together, and as the parties have agreed that there should be one set of costs in the circumstances, I would award costs in this appeal but not in appeal No A-758-81. 1 'Appeal to Supreme Court of Canada dismissed 14/10/76 — No Reasons. 2 *See The Queen v Compagnie Immobilière BCN Ltée, [1979] 1 S.C.R. 865; [1979] CTC 71; 79 DTC 5068. ...

That intention does not meet the standard required by Canadian — or California — law. ... While there may have been joint ownership of the HCP project which gave rise to the claimed losses, that joint ownership was designed to be — and was — only momentary. ... Q. — in this partnership? You assumed that as a fact? A. Yes, I did. ^ [36] These vital facts cannot be assumed. ...

MONAGHAN J.A.   BETWEEN: 2093271 ONTARIO INC., 2013674 ONTARIO INC., COLUMBIA HIGHRISE WINDOWS AND RAILIN G S INC. and COLUMBIA HIGHRISE WINDOWS GROU P INC. ... REASONS FOR JUDGMENT OF THE COURT BY: LASKIN J.A.   Date: 20240318 Docket: A-34-23 Citation: 2024 FCA 50 CORAM: LASKIN J.A. ...

The argument that Gustav Schickedanz controlled the respondent by virtue of paragraph 251(5)(b) of the Act is founded upon the terms of four trust indentures — identical in all material respects — pursuant to which a majority of the shares in the respondent were held. ...

This information indicates that, as counsel for the respondent stressed, the plan was intended to benefit mainly Mr Germain and his wife: Contributions Contributions for past for current Participants service servsice service $ $ Maurice Germain 142,220 450 George E Jolicoeur NIL 1,254 Bruno Lavigne NIL 209 Claude Germain NIL 628 Pierre Quennel NIL 26 Lucie D Germain 68,640 3,000 “It is possible to say a great deal about the legal consequences under Quebec law of the adoption by appellant of the pension plan and of the concluding of the alleged donor contract. ...

Scientific Research and Experimental Developments (SR & ED) SR & ED expenditures claimed by taxpayers, which have been accepted by the Department as so qualifying, are not to be deducted in the calculation of resource profits. 2. ... General & Administrative Expenses (G & A) The allocation of G & A for purposes of computing resource profits is as set out in the September 16, 1993 letter from the Canada Association of Petroleum Producers, a copy of which is attached. ... Trinidad & Tobago (Attorney General): [31] The principles applicable to a plea of res judicata are not in doubt and have been considered in detail in the judgment of the Court of Appeal. ...

This amount was allocated by the agreement as follows: Land $ 662,500 Buildings and other improvements $ 450,000 Personal property including furniture, furnishings, dishes, linen, utensils, and similar equipment $ 12,500 $1,125,000 In assessing the respondent's tax for the year 1976 the Minister accepted this allocation. ... Land $ 662,500 Buildings and other improvements $ 450,000 Personal property including furniture, furnishings, dishes, linen, utensils, and similar equipment $ 12,500 $1,125,000 Both parties, obviously, attached no value to so-called intangibles. ... Muller & Co.’s Margarine Ltd., [1901] A.C. 217 at 223, per Lord Macnaghten, who went on:... ...

On March 14, 1973, this Syndicate, in an arm’s length transaction, sold the Bel Air Apartments in Edmonton to knowledgeable real estate operators,* [1] for $5,850,000 which was allocated pursuant to the agreement between the parties as follows: to land — $5,100,000 and to “equipment, buildings, roads, sidewalks etc” — $750,000. It should be noted that on March 7, 1973, Skalbania made an unsolicited offer for the same Bel Air Apartments without prior negotiation or consultation, of $5,600,000 subject to the following valuation breakdown: land — $2,600,000; buildings — $2,400,000; and “trucks, equipment, roads etc” — $600,000. ...

In his memorandum counsel for the Crown relied on both the exclusion from foreign investment income in subparagraph (ii) of paragraph 129(4)(a) — income from a source outside Canada that is “property used or held by the corporation in the year in the course of carrying on a business” — and on the exclusion in subparagraph (iii) — income from a source outside Canada that is income from an active business — but in his oral submissions he rested his case squarely on the first exclusion. ... In The Queen v Marsh & McLennan, Limited, Court File A-675-81, Judgment April 11, 1983, this Court had to consider the exclusions from Canadian investment income as defined by section 129 in relation to interest earned by an insurance broker on the short term deposit of unremitted premiums — that is, the total amount from time to time of premiums (after deduction of the broker’s commission) that had been collected from insured but had not yet been remitted to the insurers. ... For the reasons which I briefly indicated in Marsh & McLennan I am of the Opinion that the same view must be taken of the interest on the US dollar deposits in the present case. ...