Archives: Case Summaries
99 DTC 905
Tax Court of Canada
August 18, 1999
(Court File No. 97-2105(IT)G.)
Inclusions in income — Royalties — Corporate taxpayer in receipt of certain royalty payments — Later, taxpayer no longer receiving such payments directly, but Minister including…
Tax Court of Canada
January 24, 2001
(Court File Nos. 1999-464(IT)G, 1999-466(IT)G, 1999-467(IT)G, 1999-468(IT)G, 1999-469(IT)G, 1999-472(IT)G, 1999-473(IT)G, 1999-474(IT)G, 1999-475(IT)G, 1999-476(IT)G, 1999-478(IT)G, 1999-479(IT)G, 1999-480(IT)G, 1999-481(IT)G, 1999-482(IT)G, 1999-484(IT)G, 1999-486(IT)G, 1999-487(IT)G, 1999-488(IT)G.)
Appeal procedure – Motions for orders holding the taxpayers’ appeals in…
2000 DTC 2353
Tax Court of Canada
July 26, 2000
(Court File No. 98-1663(IT)G.)
Scientific research and experimental development (“SR&ED”) activities — Corporate taxpayer engaged in a project based on the hypothesis that it should be possible to link a…
93 DTC 5109
Federal Court-Trial Division
February 8, 1993
(Court File No. T-819-90.)
Income or capital gain — Gain on redemption of Scientific Research Tax Credit debenture — Income Tax Act, S.C. 1970-71-72, c. 63, ss. 39(4), 127.3(6) and 194(4).…
93 DTC 5160
Federal Court of Appeal
March 24, 1993
(Court File Nos. A-675-91 and A-676-91.)
Payment of tax — Whether taxpayers liable to make instalment payments of tax with interest — Income Tax Act, S.C. 1970-71-72, c. 63, ss.…
British Columbia Supreme Court No. A920193
This was an appeal of an assessment of social services tax by the Minister of Finance and Corporate Relations of British Columbia. Two issues were involved: whether pickup trucks used by the dealership as…
95 DTC 216
Tax Court of Canada
June 30, 1994
(Court File No. 93-945(IT)G.)
Non-capital loss carryovers — Corporate taxpayer reporting a deductible loss for 1982 in respect of a second mortgage held by it — Six years later, taxpayer…
95 DTC 329
Tax Court of Canada
July 22, 1994
(Court File Nos. 92-2189(IT)G and 92-2187(IT)G.)
Investment tax credits (“ITCs”) — Taxpayers leasing buses to corporations in business of transporting passengers — Whether taxpayers’ “principal business” still constituting “passenger, property,…
96 DTC 3227
Tax Court of Canada
October 10, 1995
(Court File Nos. 86-1194(IT)O, 86-1195(IT)O and 86-1196(IT)O.)
Director’s personal liability for corporation’s unremitted source deductions — Meaning of words “deduct or withhold” and “deducted or withheld” appearing in the Act…
95 DTC 5615
Federal Court of Appeal
October 18, 1995
(Court File No. A-710-94.)
— Income Tax Act, R.S.C. 1985, Chapter 1 (5th Supp.), ss. 169 and 171.
The taxpayer appealed to the Tax Court of Canada under the Informal…