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EC decision

Minister of National Revenue v. Sheldons Engineering Limited, [1954] CTC 241, 54 DTC 1106

., said at 726 and 727 [C.T.C. at page 10]: “Two incidental questions were raised in connection with this argument. ...
EC decision

Pickle Crow Gold Mines Limited v. Minister of National Revenue, [1954] CTC 390

I am invited by the appellant to so construe it as to permit the appellant to deduct from its income for the year 1949 a proportion of the amount of pre-production expenses incurred and paid prior to July 4, 1938, by a company which until that date was entirely separate from and had no connection whatever with the appellant. ...
EC decision

St. Catharines Flying Training School, Limited v. Minister of National Revenue, [1953] CTC 362, 53 DTC 1232

Consequently, I find that the appellant was an association that was organized and operated solely for non-profitable purposes within the meaning of Section 4 (h): vide in this connection the decision of the Saskatchewan Court of Appeal in Regina Elementary Flying School Limited v. ...
TCC

Li v. The King, 2023 TCC 77 (Informal Procedure)

In 2015 he engaged his mother-in-law, who lived in the same household, to do certain work using a home laptop computer with VPN connection to his office files. ...
TCC

Robinson v. The King, 2023 TCC 122

In particular, the Court relied on Mylan where Stratas JA made the following comments in connection with a request that one proceeding be held in abeyance pending the outcome of a second proceeding: [5]...When we do this, we are exercising a jurisdiction that is not unlike scheduling or adjourning a matter. ...
FCTD

Labrosse v. Canada (Attorney General), 2022 FC 1792

Labrosse is asking the Court to accept them and consider them in connection with her application for judicial review. [30] As I explained at the hearing, the Court cannot accept these documents in a judicial review such as this one. [31] It is settled law that, in applications for judicial review, the general legal rule is that a court on judicial review can only consider evidence that was before the administrative decision maker, except for limited exceptions (Gittens v Canada (Attorney General), 2019 FCA 256 at paragraph 14; Association of Universities and Colleges of Canada v Canadian Copyright Licensing Agency (Access Copyright), 2012 FCA 22 [AUCC] at paragraphs 19–20, Aryan at paragraph 42). ...
FCA

Northbridge Commercial Insurance Corporation v. Canada, 2023 FCA 211

The supply of a financial service is an exempt supply for the purposes of the ETA, unless it is included in Part IX of Schedule VI (section 1 of Part VII of Schedule V). [16] No GST is collectible in relation to exempt supplies (section 165 of the ETA and the definitions of taxable supply and commercial activity in subsection 123(1) of the ETA) and no ITCs can be claimed for any GST paid on any goods or services acquired in connection with the making of exempt supplies (section 169 of the ETA and the definition of commercial activity in subsection 123(1) of the ETA). [17] Part IX of Schedule VI provides that certain supplies of financial services will be zero-rated supplies. ...
FCTD

Canada (National Revenue) v. Ghermezian, 2023 FC 1488

As for achieving the least expensive determination of the proceedings on their merits, the Respondents argue that, if a stay is not granted, the time, effort and expense that the parties would incur, in connection with the process of re-determining the compliance orders, may prove to be unnecessary if the SCC ultimately allows their appeal in whole or in part. [14] The Respondents contend that the delay necessary to resolve the SCC appeal will cause little prejudice to the Minister, as it will be relatively brief in comparison to the approximately eight years that these applications have been ongoing. ...
TCC

Anne-Marie Chagnon Inc. v. The King, 2023 TCC 35 (Informal Procedure)

Ultimately, she did not see any connection between research and development and the mass production of jewelry where the primary focus was the aesthetic or visual appearance of the piece. (39) On cross-examination, Ms. ...
FCTD

Broughton v. Canada (Attorney General), 2023 FC 1693

Moreover, the Second Review Reports reflect that the Officer considered not only the manner in which the Applicant had claimed that income but also the Applicant having provided limited services in connection with the rental of the boat. ...

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