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Canadian Security & Mobile Patrol Services Ltd. v. M.N.R., 2023 TCC 34 Dockets: 2019-3371(EI) 2019-3372(CPP) BETWEEN: CANADIAN SECURITY & MOBILE PATROL SERVICES LTD., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent.   ... “Patrick Boyle” Boyle J.   CITATION: 2023 TCC 34 COURT FILE NO.: 2019-3371(EI) 2019-3372(CPP) STYLE OF CAUSE: CANADIAN SECURITY & MOBILE PATROL LTD. ... PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: March 13, 2023 REASONS FOR JUDGMENT BY: The Honourable Justice Patrick Boyle DATE OF JUDGMENT: March 22, 2023 APPEARANCES:   Agent for the Appellant: Hasan Shahid Counsel for the Respondent: Amin Nur   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     ...

B & B Royalties, Ltd. v. Minister of National Revenue, [1940-41] CTC 65 MACLEAN, J. ... By an agreement (hereinafter referred to as ‘‘the Trust Agreement”) dated July 8, 1936, and made between the Company, therein called the " ‘ Operator, ‘ ‘ and The Security Trust Co. ... I have not been satisfied that the assessment should have been made against the Company and the owners of royalty interests, as an "‘associa- tion ‘ ‘; at least I presently entertain serious doubts as to whether this could be done successfully. ...

The by-laws, dealing with the rights of the preference shareholders, provided that such shares shall be "entitled out of * * * net earnings * * * to cumulative dividends at the rate of seven per cent. per annum for each and every year in preference and priority to any payment of dividends on common stock and further entitled to priority on any division of the assets of the company to the extent of its repayment in full at par together with any dividends thereon then accrued due and remaining unpaid. ... Such by-laws may provide that the holders of shares of such preference stock shall have the right to select a certain stated proportion of the board of directors, or may give them such other control over the affairs of the company as is considered expedient. * * * * 49. ... The language of the letters patent the said increased capital stock * * * shall be preference stock entitled out of any and all surplus net earnings whenever ascertained to cumulative dividends * * * in preference and priority to any payment of dividends on common stock is claimed by the appellants to limit the preference holders so far as dividends go to the rate of 7 per cent provided. ...

Pearse & Edworthy Brothers v. Rural Municipality of Bjorkdale., [1928-34] CTC 12 HAULTAIN, C.J.S. ... Trade, in its largest sense, is the business of selling, with a view to profit, goods which the trader has either manufactured or himself purchased. ‘‘ Bouvier defines mercantile law as: "‘That branch of law which defines and enforces the rights, duties and liabilities arising out of mercantile transactions and relations. ‘ ‘. ... & N. 564, 26 L.J. Ex. 82, 156 E.R, 1327; Glynn v. Thomas (1856) 11 Ex. 870, 25 L.J. ...

Crown Cork & Seal Canada Inc. v. Her Majesty the Queen, [1990] 2 CTC 465 Muldoon, J. ... Any problems may be referred to the Court as may any questions. * * * *X * His Lordship: —With respect to Suit No. ... It is a matter of fact, and the Court finds as a fact that there was no knowing misstatement or suppression of reporting of income and no circumstances amounting to gross negligence on the part of the plaintiff, Crown Cork & Seal Canada Inc. * * * * * If there be any questions, counsel may put them now or if you don't think of them right now, you may put them later. ...

If the framers of the Regulation had intended to mean the business itself, they would have used the word " thereby " or " by it " rather than the word " therein ", which latter word conveys the sense of being inside something physical. In the same vein the word " therein " can hardly apply to personnel. ... " is a hairdressing salon operating in the City of Edmonton ". ...

Tusket Sales & Service Limited v. The Queen, docket 1999-5124(GST)I (Informal Procedure) Date: 20000727 Docket: 1999-5124-GST-I BETWEEN: TUSKET SALES & SERVICE LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent. Reasons for Judgment Hamlyn, J.T.C.C. [1]            This is an appeal with respect to an assessment under Part IX of the Excise Tax Act (the " Act ") for the period January 1, 1993 to February 29, 1996, by Notice of Assessment No. 01CB0202152 dated July 17, 1996. [2]            The Appellant is a corporation involved in the sale of new and used motor vehicles. [3]            Between 1994 and 1995, the Appellant sold 14 vehicles to one Vaughn Pictou ("Pictou"), a status Indian. ... Pictou indicating that GST was paid; 6(i)           at no time did Mr. ...

Army & Navy Department Store Limited v. Minister of National Revenue, [1952] CTC 273, 52 DTC 1169, [1952] DTC 1168 ARCHIBALD, J. ... This statement is as follows: ‘ ‘ There are three companies involved in these proceedings, namely, Army & Navy Department Store (Western) Limited (hereinafter referred to as the ‘Western company’); Army & Navy Department Store Limited (hereinafter referred to as the ‘Alberta company’) and Army & Navy Department Store Limited (hereinafter referred to as the ‘Saskatchewan company’). ... Cohen) (2) The Alberta company—the shareholders are— 50 % to H. R. Cohen 10% to S. ...

Roger Mercure■ ' I v. Minister of National Revenue, [1978] CTC 2215, 78 DTC 1165 Guy Tremblay [TRANSLATION]:—The case at bar was heard at Montreal, Quebec on June 9, 1977. 1. ... The following are the expenses which were disallowed, as they appear on the tax returns: 1971 1972 1972 1973 1973 Entertainment allowance $ 835.20 $1,235.20 $4,785.00 Business taxes $ 108.00 Automobile expenses $2,775.20 $6,900.00 Fire insurance $ 244.00 $ 485.00 Office expenses $ 265.00 Telephone $ 85.00 Travel expenses $1,325.00 $3,854.40 $8,620.20 $6,568.00 Less: 25% personal use $ 963.60 $2,155.05 $2,890.80 $6,465.15 $6,568.00 3./. ...

It was held that the assessment in question was on Sifton ‘s income for 1924 and that by various enactments referred to, the municipality was prohibited from attempting to exercise jurisdiction outside the municipality and was exceeding its powers to " " levy on the whole rateable property within the municipality.’’ ... It is, I think, incontrovertible that neither plant nor equipment is, in such sense, " " paid for ‘ ‘ by the Crown. ... It is for determining " " all matters brought before the Commission’’ that the jurisdiction is declared, but those matters are such as come by way of appeal, and I see nothing in the section which introduces a new and original authority to deal with those matters in other than. the administrative manner in which they have already been dealt with: I see nothing intended to confer a purely judicial function dealing with civil rights. ...