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SCC

The King v. Fraser Companies Ltd., [1931] SCR 490

He manufactures his lumber for sale, and, as a general rule, would not manufacture any specific lumber for use in connection with his building contracts, but would simply take lumber for these purposes from the general stock manufactured for sale, and might thus, under the view taken in the court below, escape taxation on all lumber thus diverted from the general stock manufactured for sale. ...
SCC

Minister of National Revenue v. Tara Exploration and Development Co. Ltd., [1974] SCR 1057

In this connection— (i) An enterprise of one of the territories shall not be deemed to have a permanent establishment in the other territory merely because it carries on business dealings in that other territory through a bona fide broker or general commission agent acting in the ordinary course of his business as such; (ii) The fact that an enterprise of one of the territories maintains in the other territory a fixed place of business exclusively for the purchase of goods or merchandise shall not of itself constitute that fixed place of business a permanent establishment of the enterprise; (iii) The fact that a company which is a resident of one of the territories has a subsidiary company which is a resident of the other territory or which carries on a trade or business in that other territory (whether through a permanent establishment or otherwise) shall not of itself constitute that subsidiary company a permanent establishment of its parent company. ...
SCC

R. v. International Nickel Co. of Canada, Ltd., [1976] 2 SCR 675

In the words of its counsel in his opening remarks at trial: (1) “scientific research expenditures incurred by it are of a capital and not of an income nature, and are not deductible in computing profits under the jurisprudential rules developed by the Courts over a period of many years in connection with the income tax.” (2) “scientific research expenditures are not related to the production of prime metal, and thereby are not deductible by virtue of the language of Regulation 1201.” ...
FCA

Canada v. Mathers, docket ITA-8856-99

Vinette [14]       The objections raised in connection with the examination of Claudine Vinette must be dealt with as follows. [15]       On objection 2, it ultimately appears that the judgment of this Court in Markevich v. ...
FCA

Stewart v. Canada, docket A-337-98

See also s. 139(1) (ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...
FCA

Amos v. Canada, docket A-460-98

However the parties have agreed that the uses made by the Company of the leased reserve land were "related to the production of pulp", 3 the activity in connection with which the appellants were employed. ...
FCA

Long v. Canada, 2011 FCA 85

In 2002, the RCMP had investigated Mr Long in connection with an illegal marijuana growing operation, charges were laid against him, but subsequently stayed. ...
FCA

Horn v. Canada, 2008 FCA 352

Conversely, the appellants say, the Judge gave insufficient weight to the on-reserve location of the employer, to the benefits accruing to the reserve from both the employer’s presence on the reserve and its activities, and the appellants’ employment, and to Ms Williams’ residence on and Ms Horn’s continuing connections to a reserve ...
FCA

Acadia Band v. Canada (National Revenue), 2008 FCA 119

In that application, the appellant sought declarations that the Minister had a duty to consult and accommodate the appellant in connection with its Communal Sharing Tradition and in particular, in regard to the purposes and operation of the Commodity Tax and the impact on the appellant’s Aboriginal rights of decisions taken by the Minister under the GST/HST Legislation. ...
FCA

National Foundation for Christian Leadership v. Canada (Minister of National Revenue), 2005 FCA 20

The Minister's concern was that some of these donations were given in the expectation that a bursary would be granted to a student who had a family or other personal connection to the donor. ...

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