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TCC
Schutz v. The Queen, 2009 DTC 19, 2008 TCC 523
Peter Thompson [38] Peter Thompson was the Assistant Housemaster in the Powell House from September 1993 to summer 1996. ...
TCC
MacDonald v. The Queen, 2012 TCC 123, rev'd 2013 DTC 5091 [at 5982], 2013 FCA 110
[21] (1993), [1994] 1 C.T.C. 368 (F.C.T.D.), rev’d on other grounds (1994), [1996] 3 C.T.C. 74 (F.C.A ...
TCC
American Income Life Insurance Company v. The Queen, 2008 DTC 3631, 2008 TCC 306
It was noted that the trust agreement between AIL and RBC Trust Company of May 13, 1993, had certain built-in protections required by OSFI, including the Superintendent's approval for vesting an asset in trust, or withdrawing an asset vested in trust, subject to exceptions on certain assets. ...
TCC
TD Securities (USA) LLC v. The Queen, 2010 TCC 186
In a 1993 Technical Interpretation [14] the CRA first addresses the need to determine whether a particular US state’s LLCs should be considered corporations or partnerships based upon their particular characteristics. [15] The CRA went on to say that, if an LLC is treated as a partnership for purposes of the US Code such that the partners rather than the company are liable to tax on the company’s income, the LLC will not be considered a resident of the US for purposes of the US Treaty. ...
TCC
Staltari v. The Queen, 2015 DTC 1130 [at at 818], 2015 TCC 123
Bayview was a property management company set up in 1993 that did not own any property of its own. [15] 841133 and Cadboro were inactive. ...
TCC
Continental Bank of Canada v. The Queen, 94 DTC 1858, [1995] 1 CTC 2135 (TCC), aff'd at 98 DTC 6501 (SCC) after being, rev'd 96 DTC 6355 (FCA)
Canada, [1993] 4 S.C.R. 695, [1994] 1 C.T.C. 40, 94 D.T.C. 6001. The IRC v. ...
TCC
George Weston Limited v. The Queen, 2015 TCC 42
Canada, [1993] 4 S.C.R. 695, par. 42-43). I also note that expert testimony on industry practice and on accounting principles related thereto was accepted as being relevant in Echo Bay Mines Ltd. v. ...
TCC
Coopers & Lybrand Limitéé v. MNR, 94 D.T.C 1626, [1994] 2 CTC 2244 (TCC)
The Court received the last written pleading on September 7, 1993. The parties filed particularly detailed submissions. ...
TCC
Klotz v. The Queen, 2004 DTC 2236, 2004 TCC 147, aff'd 2005 DTC 5279, 2005 FCA 158
., [1993] 1 C.T.C. 2440 at 2443. 4 This is not simply an extrapolation from the rule in Hodge's Case (1838) 2 Lewin 227; 168 E.R. 1136, applicable in criminal matters such, for example, as section 239 of the Income Tax Act where proof beyond reasonable doubt is required. ...
TCC
Pièces automobiles Lecavalier Inc. v. The Queen, 2014 DTC 1126, 2013 TCC 310
[9] In 1993, following an estate freeze, the four children of Roger Fugère Senior became shareholders in the company. ...