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TCC

Wywijas v. The Queen, 2022 TCC 52 (Informal Procedure)

I say this because, had I been satisfied that the agreement came from a third party, I would have considered it to be strong evidence that Mr. ...
TCC

Romeril v. R., [1999] 1 CTC 2535, 99 DTC 221

This Appellant’s circum- stances are quite distinct from those considered by Sarchuk J. in Faubert v. ...
TCC

Samson Holdings Ltd. v. R., [1998] 4 CTC 2776, 99 DTC 218

The 1992 instalment cannot be considered an instalment made for the 1991 Part 1.3 liability, which was unknown at that time by the Minister. ...
TCC

Nach v. R., [1998] 4 CTC 2873

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Hirst v. R., [1999] 4 CTC 2026 (Informal Procedure)

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Scherbakov v. R., [1999] 4 CTC 2073 (Informal Procedure)

[2] Cullen, J. considered the requirements of section 230 and stated as follows: Section 230 of the Act requires taxpayers to keep adequate books and records. ...
TCC

Fitzpatrick v. R., [1999] 4 CTC 2420 (Informal Procedure)

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Basque v. R., [1999] 4 CTC 2525

In arriving at the quantum of the award, the Court took into account the salary of the Appellant and applied it to a notional period of employment which it considered should have been given to the Appellant prior to the termination of his employment. ...
TCC

Hunt v. The King, 2022 TCC 128

This was not a test case or lead case, and this factor should not be considered. ...
TCC

John v. R., 98 D.T.C. 1324, [1998] 2 C.T.C. 2129

The proper approach must be a functional one, and the scheme must be considered as a whole, taking into account the intent of the legislation, its object and spirit and what it actually accomplishes (cf. ...

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