Duha printers western ltd. v the queen

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August undefined, 2024

WebVineland Quarries and Crushed Stone Ltd. v. MNR, [1966] C.T.C. 69 Duha Printers (Western) Ltd. v. Her Majesty the Queen [1998] 1 S.C.R. 795 Parthenon Investment … WebApr 27, 2006 · In Duha Printers (Western) Ltd. v. The Queen the Supreme Court of Canada stated that the test for de jure control is whether the majority shareholder enjoys “effective control” over the “affairs and fortunes” of the corporation. The Supreme Court also stated that in order to determine whether such “effective control” exists, one ...

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WebLudco 5 IACOBUCCI J.:— I. Introduction ¶ 1 In this appeal, we are asked to decide whether interest charges incurred with respect to money the appellants borrowed to purchase shares in two foreign companies are deductible from their income from other sources pursuant to s. 20(1)(c)(i) of the Income Tax Act, R.S.C. WebView 3. E. Association Prediction.pdf from ACCT 428 at Grant MacEwan University. Associated Corporations and Control 7 Apr 2024 Prediction Report Predicted Outcome Not prima health center

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WebMar 19, 2001 · Duha Printers (Western) Ltd., [1998] 1 S.C.R. 795; 225 N.R. 241, refd to. [para. 39]. Continental Bank Leasing Corp. v. Minister of National Revenue, [1998] 2 S.C.R. 298; 229 N.R. 58, refd to. [para. 52]. Spire Freezers Ltd. v. Minister of National Revenue, [2001] 1 S.C.R. 391; 266 N.R. 305, refd to. [para. 52]. Backman v. WebThis page regroups all the Supreme Court of Canada's decisions on tax issues from 1920 onwards. They are divided by decade and, when available, linked to the full text provided … Webv. R.,14 Hickman Motors,15 Neuman,16 and Duha Printers,17 were heard and overturned by the SCC on the basis that each of these decisions involved bona fide legal transactions, regardless of how unrealistic the series of transactions was. In each of these cases, the SCC avoided making any reference to Bronfman Trust or the economic realities ... primahealth credit payment

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WebDuha Group is the world leader in the design and manufacturing of colour sampling tools. We specialize in precise colour matching, colour trend forecasting, and the production of … http://canadian-accountant.com/content/practice/the-general-anti-avoidance-rule-and-family-surplus-strips prima health loginWebOct 1, 2024 · Duha Printers (Western) Ltd. v. R. , [1998] 1 S.C.R. 795, para. 35 (“It has been well recognized that, under the Income Tax Act, “control” of a corporation normally refers to de jure control and not de facto control.”); prima health care ohio

"WebSupreme Court of Canada’s decision in Duha Printers (Western) Ltd. v. R. 4 for the proposition that the term “going concern” is just another way of stating that a business is being carried on with a reasonable expectation of profit. The Tax Court also rejected NRT’s argument that it was carrying on Telepanel’s ESL business " - Duha printers western ltd. v the queen

Duha printers western ltd. v the queen

1999 CanLII 647 (SCC) Shell Canada Ltd. v. Canada CanLII

Web[1998] 1 R.C.S. DUHA PRINTERS c. CANADA 795 Duha Printers (Western) Ltd. Appellant Duha Printers (Western) Ltd. Appelante v. c. Her Majesty The … WebDans Duha Printers, la Cour a rétabli le critère de contrôle de Buckerfield’s et elle a défini un fondement schématique pour déterminer la personne (s’il y en a une) qui contrôle une …

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Web1. Duha Printers (Western) Ltd. v.Her Majesty the Queen (F.C.A.)(Man.)(25513) [...] Canadian Charter of Rights and Freedoms - Criminal law - Search and seizure - Whether the Federal Court of Appeal erred in holding that prior judicial approval based upon reasonable grounds on oath is required before Canadian officials can request a foreign … WebSep 30, 2013 · In The Queen v. PwC as Trustee in Bankruptcy for Bioartificial Gel Technologies (Bagtech) Inc., 2013 FCA 164 (Bagtech), the Federal Court of Appeal…

WebAug 13, 2024 · The court also addressed the 1998 decision of the Supreme Court of Canada in Duha Printers: [8] in that case (which pre-dated GAAR), the court stated that it is … WebSep 30, 2013 · FCA Confirms Scope of Duha Printers Published by Ian Gamble In The Queen v. PwC as Trustee in Bankruptcy for Bioartificial Gel Technologies (Bagtech) Inc., …

WebTwenty-three years ago, this Court held in Duha Printers (Western) Ltd.v. R.1that control in the Income Tax Act,2if not otherwise legislatively defined, means de jurecontrol, which the Court equated with effective control. WebMay 3, 2010 · Her Majesty the Queen in Right of the Province of British Columbia (appellant/respondent) (CA037434; 2010 BCCA 255) Indexed As: Terasen Gas Inc. v. British Columbia

WebIn that case, Duha Printers (Western) Ltd. ("Duha") decided to acquire the shares of an inactive company, Outdoor Leisureland of Manitoba, from Marr's Leisure Holdings in order to take advantage of Outdoor's non-capital losses.

WebJun 29, 2012 · (3) Duha Printers (Western) Ltd v The Queen, 98 DTC 6334 (SCC). (4) [1993] 2 CTC 2087 (TCC). (5) Section 146 (1) of the Canada Business Corporations Act. … platinum tps200cWebthe business as manifested in either constating documents of the corporation or any Unanimous Shareholders Agreement. (See Duha Printers (Western) Her Majesty the … platinum trading academy reviewsWebApr 11, 2024 · In particular, in the decision of the Supreme Court of Canada (“SCC”) in Duha Printers (Western) Ltd. v. The Queen(“Duha”),6the SCC explained that the test is an attempt to determine who is in a position to have “effective control of the affairs and fortunes of a corporation”.7 platinum trading companyWebMay 28, 1998 · Duha Printers (Western) Ltd. Supreme Court of Canada L'Heureux-Dubé, Gonthier, McLachlin, Iacobucci, Major, Bastarache and Binnie, JJ. May 28, 1998. … platinum toys utah platinum trading hoursWebIn particular, in the decision of the Supreme Court of Canada (“SCC”) in Duha Printers (Western) Ltd. v. The Queen(“Duha”),6the SCC explained that the test is an attempt to determine who is in a position to have “effective control of … platinum trainingWebMay 28, 1998 · Duha Printers (Western) Ltd. Appellant v. Her Majesty The Queen Respondent Indexed as: Duha Printers (Western) Ltd. v. Canada File No.: 25513. … platinum trailers hot springs ar