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FCA

The Queen v. Gurd's Products Co. Ltd., 85 DTC 5314, [1985] 2 CTC 85 (FCA)

The respondent alleges in this case that the operations giving rise to the profits arose outside of Canada specifically, the contract for the sale of the concentrate was negotiated in Lebanon and executed in the United States. ...
FCA

The Queen v. Morrissey, 89 DTC 5080, [1989] 1 CTC 235 (FCA)

Abbott: As the hon. member will recall, this was the section which referred to the principal source of income, and then section 13(1) was introduced last year as a loophole section to cover what, for want of a better term, I shall call the hobby farmers Mr. ...
FCA

The Queen v. Mara Properties Ltd., 95 DTC 5168, [1995] 2 CTC 86 (FCA), rev'd 96 DTC 6309, [1996] 2 SCR 161

.); FA & AB Ltd. v. Lupton (Inspector of Taxes), [1971] 3 All E.R. 948 (H.L.); Québec (Deputy Minister of Revenue) v. ...
FCA

Louis Vaillancourt v. Her Majesty the Queen and Canada Mortgage and Housing Corporation, [1991] 2 CTC 42

Marsh & McLennan, Ltd., [1984] F.C. 609; [1983] C.T.C. 231; 83 D.T.C. 5180 at 244 (D.T.C. 5191; F.C. 627), Clément, D.J.; Golden v. ...
FCA

Dominion of Canada General Insurance Co. v. The Queen, 86 DTC 6154, [1986] 1 CTC 423 (FCA)

The final question is simply this whether the words of paragraph 85(1)(e) of the Income Tax Act interpreted in their plain, ordinary and grammatical sense in context of the statutory scheme of section 85B reach out to bring within the tax net in 1969 the unearned premium reserve of $10,454,396 deducted in 1968. ...
FCA

The Queen v. Placer Dome Inc., 92 DTC 6402, [1992] 2 CTC 99 (FCA)

Counsel for the respondent put great emphasis on the statements which appear in Article IV F of the plan to the effect that the employer's contribution is "on behalf of and as an absolute benefit for (the) member" and that such contribution shall be regarded as additional compensation paid to (the member)"; they likewise attach much importance to the fact that income taxes for participating employees are withheld not only from their wages but also from the employer's contribution. ...
FCA

The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065, [1996] 2 CTC 55 (FCA)

.: This is an appeal from a judgment of the Trial Division allowing in part the respondent’s appeal from the reassessment of its income tax for the 1978 taxation year. ...
FCA

The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6607, [1990] 2 CTC 448 (FCA)

.: I have had the advantage of reading the reasons for judgment prepared by my brother Urie, J.A. ...
FCA

Prince Rupert Hotel (1957) Ltd. v. The Queen, 95 DTC 5227, [1995] 2 CTC 212 (FCA)

., as he then was, in London & Thames Haven Oil Wharves Ltd. v. Attwool (1966), 43 T.C. 491, at page 515: The question whether a sum of money received by a trader ought to be taken into account in computing the profits of gains arising in any year from his trade is one which ought to be susceptible of solution by applying rational criteria. ...
FCA

Bellingham v. The Queen, 96 DTC 6075, [1996] 1 CTC 187 (FCA)

The precise scope of the residual category- windfall gains has proven problematic. ...

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