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FCTD
Deputy Attorney General of Canada, and Department of National Revenue v. Transport Voyer, Inc. And Dumas & Voyer, Ltee. And Her Majesty the Queen in Right of Canada, [1989] 1 CTC 5
And Dumas & Voyer, Ltee. And Her Majesty the Queen in Right of Canada, [1989] 1 CTC 5 Pinard, J. ... DXD 635902" — is not specified in any of the three deeds of pledge mentioned above. ...
TCC
Tillsonburg Glass & Mirror Limited v. Minister of National Revenue, [1985] 1 CTC 2345, 85 DTC 307
Tillsonburg Glass & Mirror Limited v. Minister of National Revenue, [1985] 1 CTC 2345, 85 DTC 307 Christie, ACJTC:—This appeal is concerned with a claim by the appellant to entitlement to deduct farming losses in its 1980 taxation year in an amount in excess of $5,000. ... For the purposes of this appeal, it did: Kerr & Forbes v MNR, [1984] CTC 2071 at 2073; 84 DTC 1094 at 1096. ...
FCTD
TDX Exploration & Mining Ltd. v. R., [1999] 4 CTC 148, 99 DTC 5405
TDX Exploration & Mining Ltd. v. R., [1999] 4 CTC 148, 99 DTC 5405 Reed J. ... Revenue Canada (Customs, Excise & Taxation) (1996), 96 D.T.C. 6347 (Fed. ...
FCTD
L & M Wood Products Ltd, North Battleford Lumber and Post Sales LTD and Glaslyn Forest Products LTD v. Minister of National Revenue, [1972] CTC 556, 72 DTC 6483
L & M Wood Products Ltd, North Battleford Lumber and Post Sales LTD and Glaslyn Forest Products LTD v. ... The plaintiffs L & M Wood Products Ltd and North Battleford Lumber and Post Sales Ltd are appealing their income tax assessments by the defendant for the taxation years 1968 and 1969. ...
EC decision
A. Janin & Compagnie Limitee v. Minister of National Revenue, [1971] CTC 158, 71 DTC 5116
Janin & Compagnie Limitee v. Minister of National Revenue, [1971] CTC 158, 71 DTC 5116 DUMOULIN, J. ... Janin & Compagnie Limitée (the appellant), operating jointly as Canit Janin Joint Venture, jointly and severally undertook to build for Quebec Cartier Mining Company (Canadian subsidiary of United Steel of America), an inland port and allied structures, in conformity with plans and specifications, for an amount of $13,233,467.00. 2. ...
TCC
Quesnel & District Minor Hockey Assn. v. R., [1997] 3 C.T.C. 2260
Quesnel & District Minor Hockey Assn. v. R., [1997] 3 C.T.C. 2260 Beaubier T.C.J.: 1 This appeal was heard at Prince George, British Columbia on April 30, 1997 pursuant to the Informal Procedure. ... Section 2: To control and operate Minor Hockey within the District of Quesnel; Section 3: To promote and inform the members of the Mutual Aid Fund, as a means of assistance to members injured in play, in authorized Hockey activities, to ensure the best possible safety standards are set and maintained by the Association. 7 After expenses, including referees' and linesmen's pay, the concession netted the following seasonal income: 1990-1 $ 3,070.27 1991-2 19,312.51 1992-3 5,573.29 1993-4 1,055.53 The concession posted advertisements for tournament breakfasts with which it had no connection. ...
FCA
H.A. Fawcett & Son, Ltd. v. The Queen, 80 DTC 6195, [1980] CTC 293 (FCA)
Fawcett & Son, Ltd. v. The Queen, 80 DTC 6195, [1980] CTC 293 (FCA) Ryan, J:—This is an appeal from the judgment of the Trial Division, dated June 4, 1979, dismissing with costs the appeal of the appellant, H A Fawcett & Son, Limited (“Fawcett Limited”), from an assessment for income tax for the taxation year 1975. ... See Masten & Fraser, Company Law of Canada (4th ed, 1941), at p 224: Where a shareholder of a company dies, his shares, as personal estate, vest in his executors or administrators... but the executors or administrators do not ipso facto become members of the company at common law, nor is the company entitled without their consent to register them as members.... ... ^would also refer to Fraser & Stewart, Company Law of Canada (5th ed, 1962), at As the definition of the word “shareholder” in s 3(n) of this Act includes the personal representatives of a deceased shareholder it would appear in the case of a company incorporated under this Act that, in the absence of a provision in the bylaws to the contrary, an executor although not registered as a shareholder could vote in respect of the deceased’s shares. ...
TCC
Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163, [1992] 1 CTC 2218 (TCC)
Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163, [1992] 1 CTC 2218 (TCC) Bowman, T.C.C.J. ... The definition of specified investment business” in paragraph 125(6)(h) of the Act applicable to the 1979, 1980 and 1981 taxation years was: (h) “ specified investment business” carried on by a corporation in a taxation year means a business (other than the business of leasing property other than real property) the principal purpose of which is to derive income from property, unless the corporation employs in the business throughout the year more than five full- time employees who are not specified shareholders of the corporation or persons related thereto. ... Ed Sinclair Construction & Supplies Ltd. Accrued management bonuses and accrued interest expenses I shall not repeat here the observations made in connection with the related appeal of Prosperous Investments Ltd. ...
TCC
Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576, [1987] 2 CTC 2311 (TCC)
Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576, [1987] 2 CTC 2311 (TCC) Brulé, T.C.J. ... Subsection 18(1) provides, in part, as follows: 18 (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) (General limitation.) — an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (b) (Capital outlay or loss.) — an outlay, loss or replacement of capital, a payment on account of capital or an allowance in respect of depreciation, obsolescence or depletion except as expressly permitted by this Part. ... Nomad Sand & Gravel Ltd., [1987] 2 C.T.C. 112; 87 D.T.C. 5343 decided by the Federal Court, Trial Division on July 16, 1987. ...
TCC
Will-Care Paving & Contracting Ltd. v. The Queen, 97 DTC 506, [1996] 2 CTC 2426 (TCC)
Will-Care Paving & Contracting Ltd. v. The Queen, 97 DTC 506, [1996] 2 CTC 2426 (TCC) Sarchuk J.T.C.C.:- This is an appeal by Will-Kare Paving & Contracting Limited from assessments of tax with respect to its 1988, 1989 and 1990 taxation years. ... To conclude otherwise would obscure the well-known distinction between manufacturing for the purpose of sale and manufacturing for the purpose of repair services, and be contrary to the plain intention of Parliament in enacting the legislation — an intention which the authorities say a proper construction of legislation must give effect to.... ... Appeal dismissed. 1 Hawboldt, supra. 2 supra at page 414-15 (D.T.C. 5429). 3 supra. 4 supra. 5 Webster’s New World Dictionary (2nd College ed.) page 1129. 6 1988 Income Tax Act, subsection 127(9) “qualified property” 7 ^Hawboldt, supra at pages 344-45 (D.T.C. 6547-48) 8 * Black’s Law Dictionary, 6 ed., page 1192. ...