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TCC

Wood v. The Queen, 2020 TCC 87

Wood on behalf of SG Marketing but were not taken into consideration. ...
FCA

The Gladwin Realty Corporation v. Canada, 2020 FCA 142

And that: if the Court [was] confined to a consideration of the language of the provisions in question, without regard to their underlying rationale, it would seem inevitable that the GAAR would be rendered meaningless [Copthorne, para. 111, citations omitted]. ...
TCC

1089391 Ontario Inc. v. The Queen, 2020 TCC 129

Judicial review or other consideration of the manner in which the Minister exercises her discretion is not within the jurisdiction of this Court. [17] Given that lack of jurisdiction, there is no point in considering in these Reasons whether an application for a rental property rebate is a return or information for the purposes of subsection 281(1) of the ETA. [19]   While the tragic and untimely death of Mr. ...
TCC

DiCaita v. The Queen, 2021 TCC 5 (Informal Procedure)

In any event, it is not surprising that a unit in a good state of repair is able to command a higher rent than would a unit that requires many repairs [28]. [50] In conclusion, the nature and purpose of the work, when considered in the light of the foregoing factors, persuade me that the expenses here under consideration were current and not capital in nature. ...
TCC

Cudd Pressure Control Inc. v. Her Majesty the Queen, [1995] 2 CTC 2382, 95 DTC 559

A literal or legalistic interpretation must be avoided when the basic object of the treaty might be defeated or frustrated insofar as the particular item under consideration is concerned. ...
TCC

Abilio Esteyes and Jose Cosme v. Her Majesty the Queen (Informal Procedure), [1995] 1 CTC 2884

Esteves was paid a consideration of $10 to make up the real labourer’s wage. ...
TCC

Armand Brunet v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2246

., [1985] 2 C.T.C. 2054, 85 D.T.C. 419, a number of propositions are enumerated which are applicable to ascertaining relevant intentions in relation to “trading cases” of the kind under consideration. ...
TCC

Roger Coderre, Daniel Marcoux, Pierre Daneau, Denis Coderre, Raymond Brisson, Madeleine Coderre and St. Germain Transport Ltée v. Minister of National Revenue., [1993] 1 CTC 2564, [1993] DTC 381

Consequently, I would ask the parties to submit for my consideration a draft formal judgment concerning the corporation's assessment for the year 1984. ...
TCC

Florianne Cardinal, Michel Beaudry, Beaudry Construction (Quebec) Ltée and Jeannine d'AMOUR v. Minister of National Revenue, [1992] 1 CTC 2437

The evidence is to the effect that the intermediate prerequisites for the shopping centre took too much time to fall into place, which allowed for the construction of other shopping centres. 4.03.3(10) There are considerations concerning important points, but the crucial point is this: is there sufficient substantial evidence confirming the oral testimony of the appellants as to their original intention to build a shopping centre? ...
TCC

Emilio S. Binavince v. Minister of National Revenue, [1991] 2 CTC 2580, 91 DTC 1225

To deal with these issues, I believe requires a consideration of sections 7, 11 and 15 of the Charter. ...

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