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TCC
Gold Line Transport Ltd. v. MNR, 92 DTC 2005, [1992] 2 CTC 2561 (TCC)
McKean & Archibald Randolf, [1876] 16 N.B.R. 299; 3. M.N.R. v. Wardean Drilling Ltd., [1969] 2 Ex. ...
TCC
Prévost v. MNR, [1996] 1 CTC 2701 (TCC)
.: — In 1978, François Prévost In (FPI) operated a real estate brokerage business in Québec. ...
TCC
Fickes v. The Queen, 94 DTC 1969, [1994] 1 CTC 2884 (TCC)
That was the reasoning adopted by the Supreme Court of Canada in Steer, supra, and in Stewart & Morrison Ltd. v. ...
TCC
Revelations Research Ltd. v. MNR, 92 DTC 1036, [1992] 1 CTC 2136 (TCC)
This surely would include repeatable experiments in which the steps, the various changes made and the results are carefully noted. 1 lt reads: 194. (2) In this Act, the “Part VIII refund" of a corporation for a taxation year means an amount equal to the lesser of (a) the aggregate of (i) the amount, if any, by which the scientific research and experimental development tax credit of the corporation for the year exceeds the amount, if any, deducted by it under subsection 127.3(1) from its tax otherwise payable under Part I for the year, and (ii) such amount as the corporation may claim, not exceeding 50% of the amount, if any, by which (A) the aggregate of all expenditures made by it after April 19, 1983 and in the year or the immediately preceding taxation year each of which is an expenditure (other than an expenditure prescribed for the purposes of the definition “ qualified expenditure" in subsection 127(9) claimed under paragraph 37(1)(a) or (b) to the extent that such expenditure is specified by the corporation in its return of income under Part I for the year exceeds the aggregate of (B) the aggregate of all expenditures each of which is an expenditure made by it in the immediately preceding taxation year, to the extent that such expenditure was included in determining the aggregate under clause (A) and resulted in (I) a refund to it under this Part for the immediately precedingtaxa- tion year, (II) a deduction by it under subsection 37(1) for the immediately preceding taxation year, or (III) a deduction by it under subsection 127(5) for any taxation year, and (C) twice the portion of the aggregate of amounts each of which is an amount deducted by it in computing its income for the year or the immediately preceding taxation year under section 37.1 that can reason ably be considered to relate to expenditures that were included in determining the aggregate under clause (A); and (b) the refundable Part VIII tax on hand of the corporation at the end of the year. 2 information Circular 86-4R was issued on September 25, 1987. 3 As will be seen from what has already been said in relation to Professor Snelgrove's evidence, the three criteria referred to in paragraph 2.10 of 1C86-4R2 are the criterion of scientific or technological advancement, the criterion of technologi cal uncertainty and the criterion of scientific and technical content. ...
TCC
Vander Nurseries Inc. v. The Queen, 95 DTC 91, [1994] 2 CTC 2347 (TCC)
Appeal dismissed. 1 The exact date of the approval of the loan by CIBC is not known other than it was sometime after June 13, 1985. 2 Thorne, Ernst & Whinney and Thorne, Riddell which are referred to in certain docu ments are predecessors of Peat, Marwick, Thorne. 3 By consent of both parties copies of the originals were filed. 4 Such as, inter alia, a failure to give notice of the redemption to Fantasy as required by clause 31.7(b) of theAppellant's articles; a failure to make payment of "a sum equal to the redemption” as required, cancel the shares or entry of the transaction in the share register. ...
TCC
Leung v. MNR, 91 DTC 1020, [1991] 2 CTC 2268 (TCC), rev'd 93 DTC 5467 (FCTD)
Orkin & An. (1935, A.D. 18).) It is inappropriate to speak about "reducing" a "thought" or reducing a mental process. ...
TCC
Kaiser v. The Queen, 95 DTC 13, [1994] 2 CTC 2385 (TCC)
& F. 85 at page 144 (U.K. H.L.):...the only rule for the construction of Acts of Parliament is, that they should be construed according to the intent of the Parliament which passed the Act. ...
TCC
Sun Life Assurance Co. of Canada v. R., 97 DTC 422, [1997] 3 C.T.C. 2593 (TCC)
This right has been recognized as an inherent attribute of the ownership of land since the earliest times as reflected in the maxim, “[c] ujus est solum, ejus est usque ad coelum et ad inferos ” [“to whomsoever the soil belongs, he owns also to the sky and to the depths”] (Butler v. ...
TCC
Stanley v. M.N.R., docket 95-1612-UI
Margeson" J.T.C.C. [1] See the procedure outlined in R. v. ...
TCC
Gupta v. The Queen, docket 96-1024-IT-I (Informal Procedure)
I lost in excess of $150,000 + loss in currency depreciation in Canada since then. ...