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FCTD

Twentieth Century Fox Film Corp. v. The Queen, 85 DTC 5513, [1985] 2 CTC 328 (FCTD)

On or about January 2, 1973 all of the assets of Fox Canada, except the real property located in Calgary, Alberta were transferred to the Plaintiff in consideration for the Plaintiff assuming all of the obligations of Fox Canada. 7. ...
FCA

Price v. Canada, 2013 DTC 5024 [at at 5615], 2012 FCA 332, aff'g 2011 DTC 1334 [at 1879], 2011 TCC 449

Since, in his view, disability insurance payments or wage loss replacement payments are not received in consideration of employment services rendered, they are excluded from the ambit of that subparagraph: Blauer at para. 16 ...
TCC

Sicurella v. The Queen, 2013 DTC 1124 [at at 662], 2013 TCC 79 (Informal Procedure)

Capital cost allowance calculation   [19]         With respect to capital cost allowances of a property, various considerations apply. ...
TCC

Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260, [1995] 1 CTC 2087 (TCC), briefly aff'd 98 DTC 6060 (FCA)

. $1,068,436.57) from the said active business of exploring for oil and natural gas carried on by it in the U.S. 7, On or about May 1, 1984, Phillips subscribed for 90,000 shares of the common stock of Trans World U.S. for a total consideration of U.S. $7,560,900 (or Cdn. $9,711,990). 8. ...
TCC

Follwell v. The Queen, 2011 DTC [at at 1709], 2011 TCC 422 (Informal Procedure)

  [3]      The Respondent maintains that the Appellant is an employee and he has been assessed as having received employment income in the amount of $3,119.00 paid to him by Queen’s in the subject year in consideration of the performance of his coaching duties ...
TCC

Imperial Oil Ltd. v. The Queen, 2003 DTC 179, 2003 TCC 46, aff'd 2003 FCA 289

Second, a rather wide ranging attack on the appellants' right to appeal, including allegations that that this court has no jurisdiction, that the appeals are frivolous, vexatious and an abuse of process is hardly an attack on an irregularity. [21]     I pass then to a consideration of the merits of the motions. ...
FCTD

Canadian Council of Christian Charities v. Canada (Minister of Finance), 99 DTC 5337, [1999] 3 CTC 123 (FCTD)

No doubt with this litigation in mind, and the possibility that statutory reforms may be under consideration, the Council made a request to the Minister of Finance under the Access to Information Act R.S.C. 1985, c. ...
TCC

Continental Lime Ltd. v. R, 99 DTC 1154, [1999] 3 CTC 2525 (TCC)

Again, taking the entire activity into consideration, the bagging is a final stage of processing. ...
FCA

Crowe v. Canada, 2003 DTC 5288, 2003 FCA 191

" as inapplicable to the Alberta Provincial Judges' Association since judges are not "public servants" for this purpose. [50]            The term "public servants" has a general meaning in both ordinary speech and the law which does not include judges and which fits comfortably with the purpose and context of the provision of the Income Tax Act under consideration here. ...
TCC

Fecteau v. The Queen, 2003 DTC 146 (TCC)

Whether a reasonable expectation of profit existed may be a factor that is taken into consideration in that analysis. 64             The Minister and the courts below made much of the fact that the appellant anticipated a capital gain from the eventual sale of the properties. ...

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