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TCC

Honeywell Limited v. The Queen, 2006 DTC 3124, 2006 TCC 325

It would do no credit to our system of justice in Canada if the courts were restricted in their consideration of the merits of a case by an ill-considered admission that is inconsistent with another position that is being advanced, particularly where it is sought to withdraw such an admission at an early stage in the proceeding. ...
TCC

Létourneau v. The Queen, 2010 DTC 1232 [at at 3656], 2010 TCC 203

Since the appellant produced no subsequent letter of resignation, she must be considered never to have resigned from position as director, and to have remained in office until the date that 9034‑1751 Québec Inc. was struck off the register. ...
TCC

Boissonneault Groupe Immobilier Inc. v. The Queen, [2013] GSTC 41, 2012 TCC 362

]   [35]         Thus, the “particular time” to be considered in determining whether the appellant reasonably expected at the time that the first use would be as contemplated by clause (B) is the later of the time at which the work was substantially completed and the time possession of the unit was so given to the third party under a lease or the unit was so occupied by the builder ...
TCC

Christensen v. The Queen, 98 DTC 1893, [1998] 4 CTC 2198 (TCC)

The expression “at arm’s length” was considered by Bonner, J. in McNichol v. ...
TCC

Greenaway v. The Queen, 2010 DTC 1065 [at at 2846], 2010 TCC 42 (Informal Procedure)

This issue was considered by Madam Justice Sharlow of the Federal Court of Appeal in the case of Lister v. ...
TCC

Dunlap v. The Queen, 98 DTC 2053, [1998] 4 CTC 2644 (TCC)

The reimbursement of these expenses cannot be considered as conferring a benefit within the terms of the Act. ...
TCC

Peragine v. The Queen, 2012 DTC 1287 [at at 3887], 2012 TCC 348

  (1) In this Act, a reference to a trust or estate (in this subdivision referred to as a “trust”) shall, unless the context otherwise requires, be read to include a reference to the trustee, executor, administrator, liquidator of a succession, heir or other legal representative having ownership or control of the trust property, but, except for the purposes of this subsection, subsection (1.1), subparagraph (b)(v) of the definition “disposition” in subsection 248(1) and paragraph (k) of that definition, a trust is deemed not to include an arrangement under which the trust can reasonably be considered to act as agent for all the beneficiaries under the trust with respect to all dealings with all of the trust's property unless the trust is described in any of paragraphs (a) to (e.1) of the definition “trust” in subsection 108(1).   ...
TCC

Audet v. The Queen, 2012 DTC 1208 [at at 3556], 2012 TCC 162 (Informal Procedure)

  [20]         Also, current commercial reality is increasingly considered sufficient to demonstrate that the expectation of dividend income justifies a capital loss deduction under subparagraph 40(2)(g)(ii) (Byram, at paragraph 19). ...
TCC

Austin v. R., 99 DTC 710, [1999] 2 CTC 2270 (TCC)

The question will arise in other cases and one issue that will have to be considered is whether to be a member of the clergy the ceremony whereby the person is set apart spiritually, or invested with the trappings of spiritual superiority, must be called “ordination” by the particular denomination. ...
TCC

Brown v. The Queen, 2006 DTC 3274, 2006 TCC 381

Canada, [2003] 2 F.C. 767, the Federal Court of Appeal considered circumstances in which certain taxpayers were co-owners of land which had been expropriated. ...

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