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TCC

Stack v. The King, 2024 TCC 163, 2024 TCC 164

Choulli had developed in the Appellants’ case, and which would be considered by the GAAR Committee. ... The assertion that other analyses were not considered by the Minister’s auditors concerning the Appellants is possible, but not necessarily more likely than not. ... Situated as preamble overtures in the replies, frankly, features rather than diminishes such salvos. [149] The Respondent shall provide a description of the “strategies” and “opportunities” considered and a description by list of those ignored and irrelevant. ...
SCC

Spencer v. R., 85 DTC 5446, [1985] 2 CTC 310 (SCC)

Thus any course by which such a serious consequence may be avoided must be carefully considered by our courts. ...
FCA

Bodine v. Canada, 2011 DTC 5084 [at at 5840], 2011 FCA 157

The judge carefully and comprehensively considered and analysed the evidence before her. ...
SCC

Hill-Clark-Francis Limited v. Minister of National Revenue, 63 DTC 1211, [1963] CTC 337, [1963] S.C.R. 452

To enable Poitras Frères to produce the logs and manufacture the lumber, the appellant made advances from time to time which were to be considered as payments on account of the purchase price of the products. ...
FCTD

Interfaith Development Education Assn., Burlington v. Minister of National Revenue, 97 DTC 5424, [1997] 3 C.T.C. 271 (FCA)

I appreciate that the organization's actions of facilitating development of youth within that setting could possibly be considered charitable. ...
FCA

Point Grey Golf & Country Club v. Canada, 2000 DTC 6217 (FCA)

In these circumstances the interest income must be considered to be income from property. [3]      The appellant argued that the test as to whether interest income is or is not from property should be based on whether the fund which generates the interest is set aside as a dedicated fund for the legitimate purposes of the club. ...
FCA

BP Oil Ltd. v. The Queen, 80 DTC 6331, [1980] CTC 408 (FCA)

The judge considered that all such fees were incurred for the purpose of keeping the service station in operation. ...
FCA

McDonald v. The Queen, 74 DTC 6644, [1974] CTC 836 (FCA)

Although he was not dealing in what is normally considered to be a subject of commerce such as commodities, the transaction from its very inception was purely speculative in character and was, in our opinion, as a matter of law, a venture in the nature of trade. ...
FCA

McNabb Family Trust v. R., 98 DTC 6001, [1998] 1 CTC 330 (FCA)

We respectfully agree with the Motions Judge that the “key factor” to be considered here is whether the appellant has an arguable case to present to a reviewing judge. ...
FCA

United Scottish Cultural Society v. Canada (Customs and Revenue Agency), 2004 DTC 6660, 2004 FCA 324

It knew or ought to have known that the information which it provided to the Department officials would be considered in dealing with the application to have its charitable status reinstated. ...

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