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TCC

Graeme Nichol v. Her Majesty the Queen, [1993] 2 CTC 2906, 93 DTC 1216

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

Intertan Canada Ltd. v. Minister of National Revenue, [1993] 1 CTC 2311, 93 DTC 354

., considered subsection 22(9) of SOR/85-2277 in relation to the effective date of the amendment to subsection 5300(1)(a) of the Regulations which deals with scientific research tax credits in the calculation of the instalment base for individuals. ...
TCC

David Robinson v. Minister of National Revenue, [1993] 1 CTC 2406, 93 DTC 254

., [1964] C.T.C. 294,64 D.T.C. 5184, Cattanach, J. of the Exchequer Court of Canada (as it then was) considered the application of subsection 8(1) of the Act, which for the purposes of the case at bar, is identical to the current subsection 15(1) of the Act. ...
TCC

Réjean Lagacé v. Minister of National Revenue, [1993] 1 CTC 2662, 93 DTC 1144

As regards the corporation, the shareholder's claim was considered to be the cancellation of a debt, that is, an extinguished debt. ...
TCC

Angelo Testa and Libera Testa v. Her Majesty the Queen, [1993] 1 CTC 2722, 93 DTC 413

The offer was not accepted for the following reasons as set out by the learned chairman of the Tax Review Board at page 2810 (D.T.C. 1601): Although the purchase price was considered adequate Mr. ...
TCC

Émile Mercier v. Minister of National Revenue, [1992] 2 CTC 2065, [1992] 2 CTC 2669

In all the big renovation stores I was not dealing with the owner, I was dealing with the manager, and I have the impression he considered it somewhat as a tip. ...
TCC

Seymour Pepper, Elaine Pepper, Dean Pepper, Brenda C. Pepper, Jody H. Pepper and York Super Pharmacy Limited v. Minister of National Revenue, [1992] 2 CTC 2259

Neither party raised the corporate structure of York Boutique, or the possible interrelationship of the two companies as any factor to be considered. ...
TCC

Cline Associates London Limited v. Minister of National Revenue, [1992] 2 CTC 2581, 92 DTC 2209

Cline had made a business decision, and that such a decision should be considered as falling within the parameters of the relevant jurisprudence. ...
TCC

Les Placements Richard Martineau Ltée v. Minister of National Revenue, [1992] 1 CTC 2170

This point has been considered many times by the courts. The decision in Taylor v. ...
TCC

Rose Marie Curylo and Edward Curylo v. M.N.R., [1992] 1 CTC 2389, 92 DTC 1250

The law shall be considered as always speaking, and where a matter or thing is expressed in the present tense, it shall be applied to the circumstances as they arise, so that effect may be given to the enactment according to its true spirit, intent and meaning. ...

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