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FCA

F.K. Clayton Group Ltd. v. MNR, 88 DTC 6202, [1988] 1 CTC 353 (FCA)

Thus, § 7601 gives the Internal Revenue Service a broad mandate to investigate and audit "persons who may be liable” for taxes and § 7602 provides the power to "examine any books, papers, records, or other data which may be relevant... ...
FCA

Shell Canada Resources Ltd. v. MNR, 84 DTC 6129, [1984] CTC 169 (FCA)

A court should ask what would the words of the statute be reasonably understood to mean by those governed by the statute? ... Appeal dismissed. 1 “In Turgeon v The Dominion Bank, [1930] S.C.R. 67 at p 71, Newcombe J noted that the maxim “... no doubt has its uses when it aids to discover intention; but, as has been said, while it is often a valuable servant, it is a dangerous master to follow. ...
FCA

Coblentz v. The Queen, 96 DTC 6531, [1996] 3 CTC 295 (FCA.)

.: This is an appeal from a decision of the Tax Court of Canada. Succinctly stated, the issue to be decided is whether a lump sum payment received by the appellant taxpayer, an American citizen and resident of Canada, is exempt from taxation in Canada by reason of the Canada-United States Income Tax Convention (1980), as amended (the “Convention”). ... (Release no. 84-128 Aug. 16/1984) The view has been expressed elsewhere that as a result of the Department of Finance’s endorsement, the Technical Explanation constitutes either an agreement or instrument within Article 31(2)(a) or (b) of the Vienna Convention or a subsequent agreement within Article 31(3)(a), rather than a supplementary means of interpretation within Article 32 of the Vienna Convention: see The Partners of Davies, Ward & Beck and Brian J. ...
FCA

Canadian Turbo (1993) Ltd. v. R., [1997] 1 CTC 130

.: This is an appeal from a judgment of the Trial Division, pronounced on May 18, 1995, which set aside a determination by the Minister of National Revenue that excise tax paid by the respondent, Canadian Turbo, on the sale of gasoline and diesel fuel was not refundable. ... (London: Sweet & Maxwell, 1977); Bryan A. Garner, A Dictionary of Modern Legal Usage, 2nd ed. ...
FCA

West Kootenay Power and Light Co. Ltd. v. The Queen, 92 DTC 6023, [1992] 1 CTC 15 (FCA)

Culver himself was very directly on point in his expert report (Appeal Book, appendix /, at page 6): Faced with a choice between the alternative of accruing or not accruing the unbilled income, I would opt for the former. ... Kohler, in A Dictionary for Accountants, 1957 edition, page 408, defines it as collectible, whether or not due. ... Gardner Mountain & D'Anbrumenil, Ltd. (1947), 29 T.C. 69, at page 93 was willing to accept "an estimate of what the future remuneration will amount to" and even "a discounting of the amount to be paid in the future.” ...
FCA

Dale v. R., 97 DTC 5252, [1997] 2 CTC 286 (FCA)

Langan, Snell’s Principles of Equity (London: Sweet & Maxwell, 1982) at 41. ... This Part as it relates to matters preliminary to the issue of the letters patent and supplementary letters patent are directory only; and no letters patent, or supplementary letters patent, issued under this Part shall be held void for any irreg- ularity, insufficiency or want of compliance herewith as respects such preliminary matter, This section does not help the appellants. ... First, I am of opinion that the phrase “consideration that includes shares, in its plain and ordinary meaning, cannot refer to consideration that consists of a simple promise to issue shares. ...
FCA

Atinco Paper Products Ltd. v. The Queen, 78 DTC 6387, [1978] CTC 566 (FCA)

Waters—Law of Trusts in Canada p 90. 2 [1895] 2 Ch 370 at 373;. 43 Digest 588, 376 approved in Re Oldfield, Old field v Oldfield, [1904] 1 Ch 549; 43 Digest 585, 339. 3 + [1897] 2 Ch 12, at 14; 43 Digest 552, 17; and see also Re Burley, Alexander v Burley, [1910] 1 Ch 215; 43 Digest 588, 377. 4 + Underhill’s Law of Trusts, supra. 5 Melroy v Lord, 4 DeG, F&J 263 at 274. ...
FCA

Nova, an Alberta Corporation v. The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA)

In effect, the respondent, by transmitting the natural gas owned by its customers, received from the facilities of the producers, acts as a sort of common carrier for the transportation of gas to the facilities of other natural gas transmission companies. « The transmission of natural gas is effectuated through what is termed "mainline pipes" for which purpose the respondent, in common with other transmission companies, utilizes compressors at intervals along the mainline pipes. ... Ltd. [[1909] 1 Ch. 218 at p. 236] Farwell L.J. said that: A written instrument must be "construed according to its sense and meaning, as collected in the first place from the terms used in it, which terms are themselves to be understood in their plain, ordinary, and popular sense, unless they have generally in respect to the subject-matter, as by the known usage of trade, or the like, acquired a peculiar sense distinct from the popular sense in the same words.... [Emphasis added.] ...
FCA

Hollinger Inc. v. R., 99 DTC 5500, [1999] 4 CTC 61 (FCA)

. /?. [18] and then would lead to an unfortunate and undesirable result. ... R. [1] *; secondly, for reasons of judicial comity; and, thirdly and most importantly, because paragraph 55(1)(c) of the Income Tax Act has been repealed and replaced by provisions which prohibit the conduct that the appellant and others engaged in in the transactions described in the reasons of Mr. ...
FCA

Westar Mining Ltd.v. The Queen, 92 DTC 6358, [1992] 2 CTC 11 (FCA)

"' In either case, of course, what is contemplated is not the mere physical act of extraction of ore or of extraction of ore and processing of the ore. ... M.N.R., supra, at page 232 [S.C.R.]: What is exempt under the latter section [subsection 83(5)] is income derived from the operation of a mine.” ...

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