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TCC
CanUtilities Holdings Ltd v. The Queen, 2003 TCC 193
Dawson, [1984] A.C. 474 (H.L.) as narrowed by the House of Lords in Craven v. ... It is clear that in resolving this question, the majority in Craven v. ... That specific question was not raised in the Craven v. White cases. That is, there was no question in the Craven v. ...
FCA
Canada v. Canadian Utilities Ltd., 2004 DTC 6475, 2004 FCA 234
.), as adopted in Craven v. White, [1989] 1 A.C. 398 (H.L.); 2. ... " This was a reference to a statement by Lord Oliver of Aylmerton in Craven v. ... This is the context in which the second and third parts of the Craven v. ...
TCC
Mathew v. The Queen, docket 1999-464(IT)G
In counsel's view, the applicable test is that set forth in Craven v. ... Gregory (hereinafter Craven v. White) (1988), 62 TC 151 (H.L.). As a result, for there to be a series, there must be a direct connection or link between transactions such that all the transactions in the series must have been preordained, in effect forming a single composite transaction. ... Accordingly, it is his contention that SRMP's transactions would be part of the series, and whether or not they were avoidance transactions is irrelevant. [156] In any event, counsel for the Respondent contended, should the Court apply the Craven v. ...
TCC
2437299 Ontario Inc. v. The King, 2023 TCC 165
One of these residential properties is situated on Craven Road in Toronto (the Craven Road property) and the other is situated on Fourth Street in Mississauga (the Fourth Street property). ... Craven Road property [13] The oral and documentary evidence establishes that the Craven Road property was a basic bungalow when purchased by the appellant for renovation and re-sale. ... Note that new extensions to the existing building are not to be included in determining degree of renovation. [35] As for the Craven Road property, I have to say that given the renovations as described above, I cannot conclude that the building in effect was “gutted”. ...
TCC
Tkach v. The Queen, docket 98-2393-IT-I (Informal Procedure)
The land at Craven- totalling 10 acres- had flat areas suitable for cultivation. ... In 1993-94, he felt some headway had been made on the Craven farm so he decided to build an equipment shed. ... Once the alfalfa and brome crops were destroyed by flooding, the Craven farm never generated any income. ...
TCC
Irene Capek v. Her Majesty the Queen, [1996] 1 CTC 2558 (Informal Procedure)
The respondent referred me to a decision of my colleague Bowman in Craven v. ... Craven v. Canada), [1995] 1 C.T.C. 2883 (T.C.C.). I concur in the conclusion he came to therein. ...
SCC
Canada Trustco Mortgage Co. v. Canada, 2005 SCC 54, [2005] 2 SCR 601, 2005 DTC 5523
The Queen, [1984] 1 S.C.R. 536; Craven v. White, [1989] A.C. 398; W. T. ... We agree with the majority of the Federal Court of Appeal in OSFC and endorse the test for a series of transactions as adopted by the House of Lords that a series of transactions involves a number of transactions that are “pre-ordained in order to produce a given result” with “no practical likelihood that the pre-planned events would not take place in the order ordained”: Craven v. ...
FCA
OSFC Holdings Ltd. v. Canada, 2001 DTC 5471, 2001 FCA 260
Dawson, [1984] A.C. 474 (H.L.) and Craven v. White, [1989] A.C. 459 (H.L.). In Craven v. White, Lord Oliver set out the approach at page 514: As the law currently stands, the essentials emerging from Furniss v. ...
TCC
MIL (Investments) S A v. The Queen, 2006 DTC 3307, 2006 TCC 460, aff'd 2007 FCA 236
We agree with the majority of the Federal Court of Appeal in OSFC and endorse the test for a series of transactions as adopted by the House of Lords that a series of transactions involves a number of transactions that are 'pre-ordained in order to produce a given result' with 'no practical likelihood that the pre-planned events would not take place in the order ordained': Craven v. ... Inland Revenue Commissioners, [1981] 1 All E.R. 865. [63] The fuller quote from Craven v. ...
SCC
Deans Knight Income Corp. v. Canada, 2023 SCC 16
Duke of Westminster, [1936] A.C. 1; Craven v. White, [1989] A.C. 398; Canada v. ... As explained in Trustco, a series of transactions involves transactions that are “‘pre‑ordained in order to produce a given result’ with ‘no practical likelihood that the pre-planned events would not take place in the order ordained’” (para. 25, citing Craven v. ...