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Judges v. Attorney-General of Saskatechwan, [1935-37] CTC 277

Attorney-General of Saskatechwan, [1935-37] CTC 277 Sir SIDNEY ROWLATT:—This is an appeal from a judgment of the Court of Appeal for Saskatchewan dated June 6, 1936, ante, p. 271, answering in the affirmative certain questions referred to the Court by the Lieutenant-Governor in Council for hearing and consideration pursuant-to the Constitutional Questions Act, c. 60 of R.S.S. 1930. ...

Canada Rice Mills Limited v. His Majesty the King, [1938-39] CTC 328

Griffin on this matter suggesting that there was no evidence to support the findings, they would mention some of the considerations which seem to afford evidence, taken together, upon which a Court could very properly come to that conclusion. ...

City of Toronto v. Lever Brothers Limited, [1942] CTC 171

As will be seen, the matter involves the consideration of s. 8 of the Assessment Act, R.S.O. 1937, c. 272. ...

Beaver Lumber Co. Ltd. v. Provincial Tax Commission, [1944] CTC 15

In the last referred to case the Supreme Court of Canada had under consideration provisions of the Income Tax Act of the Province of Alberta similar to those contained in the Income War Tax Act (Can.). ...

City of Winnipeg v. Rural Municipality of St. Vital, [1945] CTC 15

There were other matters under consideration in connection with a clash as to description of boundaries, which are not present in this action, but in other respects the conditions are identical. ...

The Credit Protectors (Alberta) Limited v. Minister of National Revenue, [1946] CTC 276

Marie [1921] 1 A.C. 288 at p. 290, where Duff J. said: ‘Their Lordships are not disposed to differ from the view pressed upon them that an agreement in order to receive effect under the statute must be very clearly made out; such an agreement, if effective, establishes a privilege in respect of taxation, and the principle is not only well settled, but rests upon obvious considerations, that those who advance a claim to special treatment in such matters must show that the privilege invoked has unquestionably been created.” ...

Desai v. Canada (Attorney General), 2025 FC 1018

I would also add that the Officer’s reasoning was consistent with the legislative regime governing the Minister’s discretion to grant relief. [11] On judicial review, the Applicant does not challenge the reasonableness of the Officer’s consideration of this central issue. [12] Instead, before this Court, the Applicant submits that he is a law-abiding citizen and he became a victim of fraud due to his poor English. ...

2012 Ruling 2010-0355941R3 - reverse subsidiary merger - 87(1) & 87(11)

As consideration for the Target Loan, Target issued a promissory note to Subco, having a principal amount of $XXXXXXXXXX (the "Target Note"). ... (c) Target subscribed for common shares of Newco for total cash consideration of $XXXXXXXXXX. ... As consideration for the transfer, Subco issued its common shares to Acquireco having an aggregate FMV equal to the aggregate FMV of all of the Target common shares so received by Subco. ...

2009 Ruling 2008-0289771R3 - Loss Consolidation

Whether loss consolidation transactions acceptable where voting power of controlling party in one of the affiliated corporations is disproportionate to participating equity interest and consideration for the losses is given. 4. ... Lossco holds Class 5 preferred shares of Lossco Sub (the "Lossco Sub Preferred Shares") which it received as consideration for the previous transfer of the Portfolio to Lossco Sub. ... Opco will subscribe for XXXXXXXXXX Newco Class II Common Shares in consideration for a cash contribution equal to the fair market value of the XXXXXXXXXX Newco Class I Common Shares held by Lossco. ...

2015 Ruling 2014-0548621R3 - Post Mortem Pipeline Planning

As consideration for all the redemptions described in Paragraph 9, the Corporation issued Debt1 to the Trust. 11. ... Upon incorporation of Newco, the Estate will subscribe for 1 Class A common share for $XXXXXXXXXX cash consideration. 25. ... The Trust will transfer XXXXXXXXXX Class F preferred shares and XXXXXXXXXX Class I preferred shares of the capital stock of the Corporation to Newco in consideration for PN1. ...

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