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EC decision

Minister of National Revenue v. Premium Iron Ores Limited, [1964] CTC 202, 64 DTC 5131

Foreign income tax was considered in C.J.R. v. Dowdall, O’Mahoney & Co., Ltd., [1952] 1 All E.R. 531, where a company resident in Eire carried on business at two branches in England. ...
EC decision

Robert Charles Simpson v. Minister of National Revenue, [1961] CTC 174, 61 DTC 1117

And, whether farming should be considered as one of his sources of income for 1957 or not, the facts establish that his chief source of income for 1957 was his interest in the dance hall business. ...
EC decision

Hill-Clark-Francis Limited v. Minister of National Revenue, [1960] CTC 303, 60 DTC 1245

Strong considered too onerous, and it also relinquished its right under contract with Poitras Freres Inc. to the bulk of that company’s 1951-52 season’s cut of lumber. ...
ABDC decision

Sejer Jensen and Donald R. Chalmers v. Her Majesty the Queen, [1966] CTC 684, 66 DTC 5408

It does not appear that the question was considered in the light of the words ‘‘making or assenting or acquiescing in making”. ...
EC decision

In Re the Dominion Succession Duty Act, v. In the Matter of Frank L. Burnet, Executor of the Will of Jean Brown, Deceased, [1958] CTC 169, 58 DTC 1109

Similar accretions possess a pecuniary value, yet would they be considered increments of the estate, or in the light of a personal benefit accruing to the heir in her own name and not through testamentary devolution? ...
ONSC decision

Jack Miller v. Leroy 8. Harron Et Al., [1956] CTC 102, [1956] DTC 1053

In this connection I have considered the following cases cited: (a) by the solicitor for Her Majesty—Commissioners of Taxation for the State of New South Wales v. ...
ONSC decision

In the Matter of the Trust Deed of Arthur Sturgis Hardy, [1955] CTC 138, [1955] DTC 1062

& Cr. 600 at 617, that it is generally considered more important that the rule of law should be settled than that it should be theoretically correct. ...
EC decision

Gordon Chutter v. Minister of National Revenue, [1955] CTC 377, 55 DTC 1239

What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being— Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making?” ...
EC decision

National Trust Company Limited (Estate of James Francis Weston) v. Minister of National Revenue, [1954] CTC 196, 54 DTC 1101

The additional cases cited and the distinctions made between the provisions of the English statutes and the Dominion Succession Duty Act have been considered and the authorities reviewed in the judgment in the appeals arising out of the will of George James Arlow reconsidered in the light of arguments of counsel, but I have been unable to reach different conclusions. ...
EC decision

Minister of National Revenue v. John James Armstrong, [1954] CTC 236, 54 DTC 1104

As the child will attain the age of 16 years on the 12th of October, 1955, the respondent was, at the time of payment of the sum of $4,000.00, bound to make monthly payments of $100.00 each under the decree nisi for a further period of five years, four and a half months, and while the sum of $4,000.00 would be the equivalent of forty monthly payments it exceeded at the time it was paid the then-present value of that number of payments, and the uncertainty of the lives of both the respondent and the child were no doubt matters considered. ...

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