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TCC

Yesac Creative Foods Inc. v. MNR, 91 DTC 413, [1991] 2 CTC 2622 (TCC)

The management of the appellant therefore considered expansion by franchising. ...
TCC

Adams v. The Queen, 96 DTC 1737, [1996] 3 CTC 2592 (TCC) (Informal Procedure)

I should note that, with respect to the real estate transactions, the very issue of their taxability was considered by Judge Hyde. ...
TCC

Sirivar v. The Queen, 2014 DTC 1052 [at at 2925], 2014 TCC 24 (Informal Procedure)

Paragraph 62(3)(c) is meant to include things that might not otherwise be considered “moving expenses” ...
TCC

Adams v. The Queen, 2005 DTC 636, 2005 TCC 237 (Informal Procedure)

At paragraph 18 of her reasons, the learned judge considered the meaning of "subcontract": 18         "Sous-traitance" [subcontracting] is defined as follows in Vocabulaire juridique, 2nd ed., Gérard Cornu (PUF), at page 774: Souse-traitance [TRANSLATION] Derived from traitant [dealing with], traiter [to deal with], Lat. tractare. * Process by which a *contractor, known as the main contractor, through an agreement called a * subcontractor, assigns to another person called the *subcontractor- under the main contractor's responsibility- all or part of the performance of the contract of *enterprise or public contract entered into with the *client (section 1, law of Dec. 31, 1975), the use of subcontracting implying that the main contractor must have the subcontractors accepted by the client. ...
TCC

Hinkley v. MNR, 91 DTC 1336, [1991] 2 CTC 2778 (TCC)

Where a place of business which was, at the outset, designed for a short temporary purpose only, is maintained for such a period that it cannot be considered as a temporary one, it becomes a fixed place of business and thus—retrospectively—a permanent establishment. ...
TCC

Astral Energy Ltd. v. MNR, 90 DTC 1844, [1990] 2 CTC 2422 (TCC)

The statutory context in which the term "source of income" was there used was entirely different from that now being considered. ...
TCC

Martin v. The Queen, 2013 DTC 1061 [at at 325], 2013 TCC 38

It appears that it can only be considered to have been intentionally deceitful. ...
TCC

Luise Zinkhofer and Bernard Zinkhofer v. Minister of National Revenue, 91 DTC 643, [1991] 1 CTC 2493 (TCC)

The respondent argues that more than just the number of voting shares must be considered in determining who controls the corporation. ...
TCC

Maheu v. The Queen, 2013 DTC 1261 [at at 1452], 2013 TCC 279 (Informal Procedure)

Finally, the appellant stated that she had not provided services to her former spouse's businesses during the period from March to August 2007 and that the amounts received during that period could not be considered as a salary as her former spouse claimed at first ...
TCC

Thomas v. MNR, 90 DTC 1806, [1990] 2 CTC 2315 (TCC)

Such company, while “dissolved”, cannot be considered to be dead for all purposes when, inter alia, by the very part of the Act that refers to dissolution (subsection 199(1) of the Act of 1929), provision is also made enabling the company to apply to the court for an order of revivor, with the express enactment that, upon the order being made, "the company shall be deemed to have continued in existence... as if it had not been struck off". ...

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