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FCA

The Queen v. B.B. Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA)

Furthermore, for the appellant’s position in this regard to prevail, one person would have to be considered a “group". ...
TCC

Fingold v. MNR, 92 DTC 2011, [1992] 2 CTC 2393 (TCC)

As director of Fobasco he agreed to the payments and advances and considered he and his brother were drawing on the capital of the corporation. ...
TCC

Dion v. The Queen, 2012 DTC 1101 [at at 3027], 2012 TCC 6

.'s name and he was registered with the brokerage service as the operator of the second truck (see Exhibit A-2(1)), and the brokerage paid R.D. directly by cheque, R.D. was considered to be operating his own business and was thus required to include the income from this source in his personal tax return ...
FCA

R. v. Kakfwi, 99 DTC 5639, [1999] 4 CTC 264 (FCA)

In any event, if the receipt of money as wages is to be considered in itself and as distinct from what was before, that is the right of the employee to be paid wages and what followed, money in the pocket of the employee, then it is clear that such a receipt does not meet the “durability” requirement the particular notion of “personal property” used in subsection 90(1) implies as discussed above. ...
TCC

506913 N.B. Ltd v. The Queen, 2012 TCC 210

The solicitor-client relationship has long been considered one of these special relationships ...
FCTD

Shindle v. The Queen, 95 DTC 5502, [1995] 2 CTC 227 (FCTD)

When considered in total perspective, the actions of Beatrice Shindle with respect to the Ontario operations were the actions, not of a company director, but, rather, those of a substantial creditor doing her very best to keep the Ontario operation going so that, hopefully, it could become a profitable operation from which, in time, the profits could be employed in repaying Evan’s large indebtedness to his parents. ...
TCC

GKN Sinter Metals - St. Thomas Ltd. v. The Queen, 2006 DTC 3025, 2006 TCC 248

The Appellant's counsel refers to this as the "protection of pre-settlement CCA". [15]The Respondent, on the other hand, argues that the amount referred to in subparagraph 5401(1)(a)(ii) is the amount of CCA that can be considered to have actually been deducted by the taxpayer in respect of the particular property. ...
FCA

ADP Canada Co.(Canadian Automatic Data Processing Services Ltd.) v. Canada, 2009 DTC 5091, 2009 FCA 117

If it is to be considered as a disbursement, it is undoubtedly one incurred by ADP’s clients.   ...
EC decision

Ancaster Development Co. Ltd. v. MNR, 61 DTC 1047, [1961] CTC 91 (Ex Ct)

If it be suggested that that case is authority for the submission made by counsel for the appellant herein that only the bare facts of the actual sale itself can be considered, I could not agree. ...
TCC

Martin v. The Queen, 2012 DTC 1253 [at at 3725], 2012 TCC 239

These circumstances must be taken into account, but must be considered against an objective "reasonably prudent person" standard. b.   ...

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