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Evans v. The Queen, 2005 DTC 1762, 2005 TCC 684

" [16] Paragraphs 23 to 26 deal with the meaning of the phrase "series of transactions" and adopt the test enunciated in the House of Lords in Craven v. ...

Scavuzzo v. The Queen, 2005 TCC 772

" A de facto director is as much in a fiduciary position as a de jure director, and liable accordingly. 99 It has further been held that what is now section 180 does not justify the claim of a person against a company for services as liquidator where, because he had not been validly appointed, he never had authority from the company to act as liquidator. 1 It would seem that the principle of this decision would also apply to a director who had been invalidly appointed or who acted after becoming disqualified, but in Craven-Ellis v. ...

Grenon v. The Queen, 2021 TCC 30

[554] As noted in Canada Trustco, the second requirement for GARR is that “the transaction giving rise to the tax benefit be an avoidance transaction” within the meaning of subsection 245(3) and that “the function of this requirement is to remove from the ambit of GARR transactions (…) that may reasonably be considered to have been undertaken or arranged primarily for a non-tax purpose” (para 21). [555] The Supreme Court has explained that the expression “series of transactions” generally refers to 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”, quoting from Craven v. ...

Ritter v. Canada (National Revenue), 2013 FC 411

DATED: April 23, 2013 APPEARANCES: George Craven FOR THE APPLICANT Wendy Bridges FOR THE RESPONDENT SOLICITORS OF RECORD: Craven Tax Law Calgary, Alberta FOR THE APPLICANT William F. ...

Clement v. R., [1996] 1 CTC 2560 (Informal Procedure)

The most recent case is the unreported reasons for judgment dated March 22, 1995, in Craven v. ... Craven v. Canada), [1995] 2 C.T.C. 2883. In that case reference is made to the “rigid criteria” set out in the legislation. ...

Maisie Winnetta Bowles v. Her Majesty the Queen, [1997] 1 CTC 2045 (Informal Procedure)

In Craven v. R., 94-2619(IT)I, I stated: The application of the inflexible tests in section 118.4 leaves the court no room to apply either common sense or compassion in the interpretation of the disability tax credit provisions of the Income Tax Act- provisions that require a compassionate and commonsense application. ...

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Albert, Stony Plain, Strathcona County, Sturgeon County, Sundance Beach, Thorsby, Wabamun 133A, Wabamun 133B, Warburg, Enoch Cree Nation Map of Edmonton Census Metropolitan Area Red Deer Red Deer Map of Red Deer Census Metropolitan Area Saskatchewan CMA and municipalities- Saskatchewan CMA Municipalities Map Regina Regina, Edenwold No. 158, White City, Pilot Butte, Lumsden No. 189, Lumsden, Balgonie, Lajord No. 128, Regina Beach, Sherwood No. 159, Grand Coulee, Buena Vista, Pense, Pense No. 160, Edenwold, Belle Plaine, Disley, Lumsden Beach, Craven Map of Regina Census Metropolitan Area Saskatoon Saskatoon, Warman, Martensville, Corman Park No. 344, Vanscoy No. 345, Dundurn No. 314, Blucher No. 343, Dalmeny, Langham, Aberdeen No. 373, Osler, Delisle, Allan, Asquith, Aberdeen, Dundurn, Vanscoy, Colonsay, Whitecap, Clavet, Shields, Colonsay No. 342, Bradwell, Thode, Meacham Map of Saskatoon Census Metropolitan Area Manitoba CMA and municipalities- Manitoba CMA Municipalities Map Winnipeg Winnipeg, Springfield, Taché, St. ...

Daggett v. MNR, 93 DTC 14, [1992] 2 CTC 2764 (TCC)

This finding brings the facts herein squarely within the anti-avoidance doctrine established by Ramsay, Burmah and Furniss, supra, as modified or limited by Craven v. ...

Lipson v. Canada, 2007 DTC 5172, 2007 FCA 113, aff'd 2009 DTC 5015 [at 5528], 2009 SCC 1

[47] In Canada Trustco, at para. 24, the Supreme Court confirmed that the expression “series of transactions” in section 245 refers to transactions that are “pre-ordained in order to produce a given result” with “no practical likelihood that the planned events would not take place in the order ordained” (Craven v. ...

Her Majesty the Queen v. Kalvan Gill, [1990] 2 CTC 318

Craven [1952], 1 All E.R. 613 relied upon by the Crown are all distinguishable either on their facts or because of dissimilarities between the statutes which they interpret and those involved in the present case. ...

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