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Under the Scientific & Research Tax Credit (SRTC) scheme, the issuer of the security, Dell, designated an amount of $7.5 million which was purchased by the plaintiff. ...

Thus, it is argued that to now treat the use of the loan as income in his hands, amounts to double taxation — the income potential for the loan has been taxed twice. ...

.: — Relief Sought The notices of motion filed respectively by Her Majesty the Queen and the other defendants seek identical remedies: namely the grant of leave to file a conditional appearance in order to object to the jurisdiction of the Court, a finding that the Court has no jurisdiction to entertain this action, and in the alternative the striking out of all or part of the statement of claim on other grounds. ...

In 1977, the plaintiff jointly purchased a 114-unit apartment building situated at 33,710 Marshall Road, Abbotsford, British Columbia (the “ Marshall Road Property") with two companies whose shareholders were his acquaintances. ...

The taxpayer had been served three notices of reassessment in one year and the issue before the Tax Review Board was whether the reassessments were ” unfair and unreasonable” treatment by the Minister. ...

.: — This is an appeal from the decision of the Tax Court of Canada dated June 18, 1991, wherein it was held that subparagraph 40(2)(g)(ii) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

The documents consist of correspondence between counsel, correspondence from Coopers & Lybrand Limited and various accounting records and memoranda pertaining to the Thrush receivables. ...

Further, it was easier in the Sani Sport case to connect the loss of business opportunity with the property because, as Marceau, J.A. pointed out, this amount represented the “ particular economic value that the land had for the expropriated party". ...

. — Every person (other than a trustee in bankruptcy) who is an assignee, liquidator, receiver, receiver-manager, administrator, executor or any other like person (in this section referred to as the "responsible representative") administering, winding-up, controlling or otherwise dealing with a property, business or estate of another person, before distributing to one or more persons any property over which he has control in his capacity as the responsible representative, shall obtain a certificate from the Minister certifying that all amounts (a) for which any taxpayer is liable under this Act in respect of the taxation year in which the distribution is made, or any preceding taxation year, and (b) for the payment of which the responsible representative is or can reasonably be expected to become liable in his capacity as the responsible representative have been paid or that security for the payment thereof has been accepted by the Minister. (3) Personal liability—Where a responsible representative distributes to one or more persons property over which he has control in his capacity as the responsible representative without obtaining a certificate under subsection (2) in respect of the amounts referred to in that subsection, the responsible representative is personally liable for the payment of those amounts to the extent of the value of the property distributed and the Minister may assess the responsible representative therefor in the same manner and with the same effect as an assessment made under section 152. ...

The season within which it can operate is short — the beginning of July to the end of September. ...