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FCTD

Ethyl Corporation of Canada Limited v. Her Majesty the Queen, [1979] CTC 21, 79 DTC 5012

In the course of his studies and experiences as a chemist and particularly in connection with his employment by the plaintiff, he has become in- formed with regard to the phenomenon of knocking in internal combustion engines and efforts that have been made to prevent or minimize its occurence. ...
T Rev B decision

Macmillan Bloedel Limited v. Minister of National Revenue, [1979] CTC 2342, 79 DTC 297

The appellant’s witness stated that, in connection with the “series C debentures”, all of the holders are resident or apparent residents of the United States. ...
T Rev B decision

Victor v Spencer and Mary Spencer v. Minister of National Revenue, [1978] CTC 2109, 78 DTC 1129

Late in 1970 they became aware of some financial difficulties in Gateway, with which they had some business connections, and also that Canada Trust Company. ...
FCA

David Cooper v. Minister of National Revenue, [1977] CTC 107, 77 DTC 5099

The appellant had been employed only a short time as a commission salesman of M Greene & Associates Limited, security dealers (hereinafter referred to as “Greene & Associates’’) when he met one Dr W N Ingham, a consulting geologist, who was at the time of their meeting doing work for Greene & Associates in connection with a mining property in which they were interested. ...
T Rev B decision

Geoffrey F Brooks v. Minister of National Revenue, [1977] CTC 2048, 77 DTC 38

This arrangement had been discontinued by him in June 1973 with regard to both direct financial support and payments in connection with the Crown Life Insurance mortgage, on the home. ...
T Rev B decision

Charles a Latimer v. Minister of National Revenue, [1977] CTC 2128, 77 DTC 84

Counsel for the respondent asserted that: the Corporation controlled what work the appellant was to do and where and when he was to do it: the Corporation supplied the appellant with an office, equipment and staff at its premises, and the appellant was not required to provide any of his own staff, supplies or equipment; the chance of profit and risk of loss with respect to services performed by the appellant was borne exclusively by the Corporation; the Corporation was responsible exclusively for utilizing and managing the appellant’s services; the Corporation deducted contributions to the Canada Pension Plan and Unemployment Insurance from the salary paid to the appellant in the taxation years 1971 and 1972; the appellant devoted all his efforts to performing the services for the Corporation and was prohibited from performing consulting services for other persons without the consent and agreement of the Corporation; the appellant did not perform services for anyone but the Corporation from July 1970 to March 1972; under the arrangement between the appellant and the Corporation the appellant was to serve the Corporation for an indefinite period; the appellant’s services were not obtained by the Corporation for a specific task of limited or definite duration; on the Annual Information Return of the Corporation as of 14 December 1973 under the Ontario Business Corporations Act, the appellant was reported as holding the office of treasurer of the Corporation commencing 20 January 1972; in the London Ontario City Directory of 1971 the appellant was named as comptroller of the Corporation; the appellant was reimbursed for all expenses incurred in connection with the services he performed for the Corporation by submitting a “service record” of the Corporation outlining the expenses incurred; the services performed by the appellant under the arrangement were an integral part of the Corporation’s business. ...
T Rev B decision

Arthur E Kruger, Elmer D Bassani and Pantel Holdings LTD v. Minister of National Revenue, [1977] CTC 2311, 77 DTC 208

In this connection, the appellant recounted that the dust problem which was associated with Inland would have probably prevented the use of the property for his original purpose, even if he had stayed associated with the mechanical contracting business. ...
T Rev B decision

Pleiad Investments Limited v. Minister of National Revenue, [1977] CTC 2546

The case of Racine, Demers and Nolin v MNR, [1965] CTC 150; 65 DTC 5098, was referred to in connection with the secondary intention argument. ...
FCTD

Virgen v. Canada (Attorney General), 2022 FC 1544

However, the intelligibility concern that arises in connection with the Decision in the case at hand relates to uncertainty whether, and if so how, Criterion 13 figures in the reasoning underlying the Decision. [43] In both its written and oral submissions, the Respondent takes the position that the Decision does not turn on the application of Criterion 13. ...
FCTD

Herbert Burke, Plaintifi, v. Her Majesty the Queen, [1976] CTC 209, 76 DTC 6075

In this connection, it appears to me that the meaning of the expression “for or under a superannuation fund or plan” is not modified or affected by the words “in effect” which I think refer only to the dues levied and the purpose for which they are levied. ...

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