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FCTD

Thomas Korisan v. Minister of National Revenue, [1971] CTC 527, 71 DTC 5278

According to this definition it is the situation in the last month of the taxation year in respect of which the expression is being applied that must be considered. ...
EC decision

Villa Capri Apartments Limited v. Minister of National Revenue, [1970] CTC 464, 70 DTC 6307

He replied that if an offer were made it would be considered. He then discussed the matter with the owners and they fixed a price of $125,000. ...
EC decision

Minister of National Revenue v. Leonard A. Braithwaite, [1969] CTC 677, 70 DTC 6001

To appreciate the point in issue on this appeal, the application of the Income Tax Act to a person who was a member of the Legislative Assembly and who had made investments such as those made by the respondent in the year in question must be considered in three stages. ...
EC decision

Settler Oils Limited v. Minister of National Revenue, [1968] CTC 252, 68 DTC 5168

The facts upon which the appellant relies for its contention that the amounts in question were not, properly considered, revenues from a business within the meaning of that word as used in the Income Tax Act were developed in some detail commencing with the time when Saskatchewan was incorporated in 1882. ...
EC decision

Palmer-McLellan (United) Ltd. v. Minister of National Revenue, [1968] CTC 448, 68 DTC 5304

To extend the statutory deduction in the converse case would add to the anomaly and open the way for borrowed capital to become involved in a complication of remote effects that cannot be considered as having been contemplated by Parliament. ...
EC decision

Minister of National Revenue v. Crossley Carpets (Canada) Limited, [1968] CTC 570, 69 DTC 5015

However it was considered by Mr. Ledingham and the appellant that one or other of them should accept the trip because Thornerest was negotiating with Ford to extend its franchise to include the Lincoln automobile produced by Ford. ...
EC decision

Minister of National Revenue v. Dorila Trottier, [1967] CTC 28, 67 DTC 5029

Alimony or maintenance whether or not paid out of the husband’s income was considered. as something to which the wife was entitled. ...
EC decision

Lou’s Service (Sault) Limited v. Minister of National Revenue, [1967] CTC 315, 67 DTC 5201

Mahon would be considered. There is no mention of an agreement not to declare dividends or not to exercise voting rights on the preference shares in any of the appellant’s corporate records so far as I can ascertain from the material before me. ...
EC decision

Mikolaj Pietrow v. Minister of National Revenue, [1967] CTC 587, 68 DTC 5008

What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being—Is the sum of gain that has been made a mere enhancement of value by realizing a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making and was approved in part in Commissioner of Taxes v. ...
TCC

Syndicat des Copropriétaires le Sommet Entre Ville et Montagnes v. M.N.R., 2022 TCC 167

The worker considered himself an employee of the appellant. The worker’s tasks included: maintaining outdoor areas; maintaining the pool, nature spa and resting surface; maintaining the indoor areas and sports facility; removing snow from entrances and walkways; managing waste (garbage) and recycling removal; administering petty cash in the amount of $200.00; and managing reservations for the reception room and guest suite. ...

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