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TCC

Resman Holdings Ltd. v. R., [1998] 4 CTC 2289, 98 DTC 1999

This was the same issue considered by the Court in the Wheeler case. The Appellants there argued that both “discovery” and “accumulation” should be given their plain and ordinary dictionary meanings such that, at most, clause (ii.l)(A) adds a requirement that the well have the ability to produce petroleum or natural gas (irrespective of from what pool such production is attained). ...
TCC

Sloan v. The King, 2022 TCC 121

You can ask him questions about what he looked at and what he considered, but it’s improper to ask us how – for our evidence on certain points. ...
TCC

Vasilkioti v. The King, 2024 TCC 101

In addition, even if these loans existed, they were not contemplated at the time of transfer of the interest in the Property, and thus, they cannot be considered as part of the consideration given by Ms. ...
TCC

Rosen v. The King, 2025 TCC 6 (Informal Procedure)

This Court considered pa r agraph 8(1)(f) and wrote: [7] P aragrap h (1)(f) …refers to amounts expended. ...
TCC

Vortex Energy Services Ltd. v. The King, 2025 TCC 63

In arriving at the answer to that question, I have considered the assumptions and the evidence under each criterion in turn. 1. ...
TCC

Standard Life Assurance Company of Canada v. The Queen, 2015 DTC 1113 [at at 687], 2015 TCC 97

Doherty considered various offshore markets that SLAC might consider entering, and provided his recommendations to Mr. ... Furbert also signed an authorization for personal information also dated December 18, 2006, a date before she was even considered for the position and while the offer was pending to Ms. ...
TCC

Les Ventes et Façonnage de Papier Reiss Inc v. The Queen, 2016 TCC 289

They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ... The Queen, 2015 TCC 182, [2016] GSTC 53, Associate Chief Justice Lamarre stated as follows: [28] As stated above, when there is an issue of gross negligence, the taxpayer’s conduct should be considered, especially if it must be determined whether the taxpayer was wilfully blind. ...
TCC

MacIntyre v. M.N.R., docket 96-223-UI

Likewise, there was no evidence to support the allegations in paragraphs 6(k), (l), (m) or (n), nor the conclusion reached in paragraph 6(o), even if the conditions referred to therein should be a factor to be considered in the contract of service argument. ... Some of the presumptions may have been rebutted and some may even have been supportive of the Appellants’ position but the ultimate result is that the significant allegations detrimental to the Appellants’ positions have not been rebutted and indeed could not have been rebutted without the evidence of the “Payor”. [413] Taken in isolation, the payment of wages in cash may not be significant, but when considered in light of the allegations of the Respondent in the Reply and in light of the failure of the Appellants to produce any corroborative evidence of payment, that fact is of significance. ...
TCC

Dipede v. The Queen, 2004 TCC 100

She considered herself to be the bookkeeper and the secretary and MacNeil was managing the office and doing estimates. ... " This, however, is evidence that the term "directors" was considered by MacNeil and he made it clear throughout that the Appellant was a party to mostly all of these meetings if not all of them and the same information was made available to the Appellant from their lawyers, accountants and auditors as was made available to MacNeil. ...
TCC

Ayre v. The King, 2025 TCC 41

Although Cattanach J. expressed the caution that his words did not constitute an “exact” definition, the extent to which his words have been adopted in the jurisprudence without change over some thirty years suggests that his approach, although not necessarily exhaustive, is now considered to be the working definition. [38] [42] In the same decision, Justice Rothstein went on to observe that: [17] In applying the Henderson definition of fair market value, the first step is to accurately identify the asset whose fair market value is to be ascertained. ... While these incentives appear to be an extension of the existing rules for charitable giving, they must be considered independently of the tax programs which support charitable giving. ...

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