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Smith, Kline & French Laboratories Ltd. v. Canada (Attorney General), docket T-2696-80

" 2. In the centre of the top margin, a "capital letter D in a circle" both in pencil. 3. At the top right in red ink the following has been hand-written: "D-146 to be sealed as confidential" 4. ... Box 130 Toronto, Ontario M5X 1A4 For the Plaintiffs George Thomson Deputy Attorney General of Canada For the Defendant FEDERAL COURT OF CANADA Court No.: T-2696-80 Between: SMITH, KLINE, & FRENCH LABORATORIES LIMITED, SMITYH, KLINE & FRENCH CANADA LTD., GRAHAM JOHN DURANT, JOHN COLIN EMMETT and CHARON ROBIN GANELLIN For the Plaintiffs - and- THE ATTORNEY GENERAL OF CANADA For the Defendant AMENDED REASONS FOR ORDER AND ORDER ...

RCF IV – Federal Court of Australia finds that gains of U.S. limited partners from sales of an Australian resource company were not Treaty exempt but were not TCP-type gains

19 February 2018- 9:19pm RCF IV – Federal Court of Australia finds that gains of U.S. limited partners from sales of an Australian resource company were not Treaty exempt but were not TCP-type gains Email this Content Two Caymans investment LPs (“RCF IV” and RCF V”) whose limited partners were mostly U.S. residents, realized gains from the disposal of shares of significant shareholdings in a TSX-listed Australian corporation (Talison Lithium) which, through a grandchild corporation, held mining leases in Australia and carried out an operation there of mining lithium ores and processing them. ... Summaries of Resource Capital Fund IV LP v Commissioner of Taxation [2018] FCA 41 under Treaties – Income Tax Conventions – Art. 3, Art. 13, s. 248(1) – taxable Canadian property – (d), s. 115(1)(a)(ii), s. 9 – capital gain. v. profit – shares, General Concepts – stare decisis, s. 152(1). ...

Smith, Kline, & French Laboratories Ltd. v. Canada (Attorney General), docket T-2696-80

" 2. In the centre of the top margin, a "capital letter D in a circle" both in pencil. 3. At the top right in red ink the following has been hand-written: "D-146 to be sealed as confidential" 4. ... Box 130 Toronto, Ontario M5X 1A4 For the Plaintiffs George Thomson Deputy Attorney General of Canada For the Defendant FEDERAL COURT OF CANADA Court No.: T-2696-80 Between: SMITH, KLINE, & FRENCH LABORATORIES LIMITED, SMITYH, KLINE & FRENCH CANADA LTD., GRAHAM JOHN DURANT, JOHN DURANT, JOHN COLIN EMMETT and CHARON ROBIN GANELLIN For the Plaintiffs - and- THE ATTORNEY GENERAL OF CANADA For the Defendant REASONS FOR ORDER AND ORDER ...

L & K Farms Ltd. v. The Queen, docket 98-570(IT)G

FEES 1. Services prior to Examination $ 375.00 2. ... Witness fees Lloyd Taylor $ 100.00 Dave Cook $ 50.00 Bill Lichfield $ 150.00 9. Witness travel D. Cook 120 kms at.35 $ 42.00 Lloyd Taylor 170 kms at.35 $ 59.50 Bill Litchfield (air travel Winnipeg to Saskatoon and return) $1,048.00 Mileage Saskatoon, Prince Albert and return (240 kms at.35) $ 84.00 Hotel and meals (estimate) $ 200.00 10. ...

A & R Dress Co. Inc. v. Canada (Minister of National Revenue), 2006 FCA 298

INTERPRETATION Definitions 2. (1) In this Act, “goods” « marchandises » “goods”, for greater certainty, includes conveyances, animals and any document in any form; Customs Tariff (1997, c. 36) PART 1 INTERPRETATION AND GENERAL Interpretation […] Words and expressions in Act 4. ... « marchandises » “ goods ” « marchandises » Leur sont assimilés, selon le contexte, les moyens de transport et les animaux, ainsi que tout document, quel que soit son support. ... DELIVERED FROM THE BENCH BY: DÉCARY J.A. DATE OF REASONS FROM THE BENCH: September 11, 2006 APPEARANCES: Michael Kaylor FOR THE APPELLANT Jacques Mimar FOR THE RESPONDENT SOLICITORS OF RECORD: Lapointe Rosenstein Montréal, Quebec FOR THE APPELLANT John H. ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 3, 2020-0851991C6 F - Shares Donation to a tax exempt entity & dividend -- summary under Subsection 129(1.2)

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 3, 2020-0851991C6 F- Shares Donation to a tax exempt entity & dividend-- summary under Subsection 129(1.2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1.2) on an excepted gift of 10% of the shares of a CCPC to a public foundation and the shares’ redemption, s. 129(1.2) could deny the CCPC’s dividend refund In order to make a donation to a registered charity and public foundation (the "Donee"), a CCPC wholly-owned by Mr. ... Furthermore, the CRA took a similar approach in … 2016-0628181R3 by adding an opinion that any dividend … paid … on the shares of … the private corporation (Holdco) to the foundation (Foundation), which had previously acquired the shares as a result of the transfer of the shares by the testamentary spousal trust for the spouse of the deceased following the death of the spouse, would be considered not to be a taxable dividend, with the result that subsection 129(1. 2) would apply …. Whether the Purpose Test is satisfied is a question of fact that can only be resolved on the basis of the facts and circumstances …. ...

Gagnon & Brisson v. M.N.R., 2008 TCC 120

[28] Ms. Dessureault also prepared a table showing the time that the Appellants spent on their catering service: Breakdown of Karine Brisson's Business Revenues – Rétro Dog 11 Year: 2005 2006 Revenues- Revenues- Revenues- Revenues- Catering Service Restaurant Catering Service Restaurant Month January $4,158.72 Februaryr $2,124.17 March $323.00 April $5,859.91 $9,791.82 May $307.85 $19,521.33 $24,267.00 June $5,501.60 $23,753.53 $1,030.58 $25,528.00 July $409.00 $28,643.67 $27,829.00 August $23,801.40 $666.82 September $16,014.03 $15,306.56 October $4,352.53 $8,309.09 November $2,419.87 $1,488.85 December $1,738.75 Total $14,729.60 $117,593.87 $9,125.32 $134,698.29 In light of this table, Ms. ... [43] For these reasons, the appeals are dismissed. Signed at Ottawa, Canada, this 7th day of March 2008. "Alain Tardif" Tardif J. Translation certified true on this 21st day of April 2008. ...

1 September 1989 Ministerial Correspondence 58434 F - Effect of SR & ED Investment Tax Credits on Calculation of "Safe Income on Hand"

1 September 1989 Ministerial Correspondence 58434 F- Effect of SR & ED Investment Tax Credits on Calculation of "Safe Income on Hand" Unedited CRA Tags 55(2), 55(5), 127(5), 12(1)(t) 19(1) File No. 5-8434 D. Watson (613) 957-2121 September 1, 1989 Dear Sirs: Re: Subsection 55(2), 55(5) and 127(5) of the Income Tax Act (the "Act") This is in reply to your letter dated July 25, 1989. ... Year 1 Taxable Income $3,000 Tax 40% $1,200 Less ITC 350 850 Safe income on hand 2,150 Year 2 Taxable Income Before 12(1)(t) $4,000 Add ITC 350 Total $4,350 Less Tax 40% 1,740 After tax income $2,610 Less ITC Income Inclusion 350 Safe Income on hand $2,260 Total safe income on hand at end of year 2 $4,410 In Year 2, the taxpayer's taxable income would be increased by $350 pursuant to paragraph 12(1)(t). ...

Installation Globale Normand Morin & Fils Inc. v. Canada (Public Works and Government Services), 2009 FC 748

Installation Globale Normand Morin & Fils Inc. v. Canada (Public Works and Government Services), 2009 FC 748 Federal Court Cour fédérale Date: 20090722 Docket: T-736-03 Citation: 2009 FC 748 [UNREVISED ENGLISH CERTIFIED TRANSLATION] Ottawa, Ontario, July 22, 2009 PRESENT: Madam Prothonotary Tabib BETWEEN: INSTALLATION GLOBALE NORMAND MORIN & FILS INC. ... “Mireille Tabib” Prothonotary Certified true translation Francie Gow, BCL, LLB FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-736-03 STYLE OF CAUSE: Installation Globale Normand Morin & Fils Inc. v. Public Works and Government Services Canada PLACE OF HEARING: Ottawa, Ontario DATE OF HEARING: June 29, 2009 REASONS FOR ORDER: Madam Prothonotary Mireille Tabib DATED: July 22, 2009 APPEARANCES: Chantal Donaldson Ekaterina Pavlova-Kraycheva FOR THE APPLICANT Yannick Landry Josianne Philippe FOR THE RESPONDENT SOLICITORS OF RECORD: LeBLANC, DOUCET, McBRIDE Gatineau, Quebec FOR THE APPLICANT JOHN H. ...

Methot & Senechal v. M.N.R., 2003 TCC 479

Signed at Ottawa, Canada, this 17th day of July 2003. “Alain Tardif” Judge Tardif Translation certified true on this 30th day of January 2004. ...

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