Gladwin Realty Corporation v. The Queen, 2019 TCC 62

CourtTax Court (Canada)
Case DateMarch 21, 2019
JurisdictionCanada (Federal)
Citations2019 TCC 62
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6 practice notes
  • Grenon v. The Queen, 2021 TCC 30
    • Canada
    • Tax Court (Canada)
    • June 1, 2021
    ...and disregard the one that was represented as being the real one” (para. 59). See also Gladwin Realty Corporation v. The Queen, 2019 TCC 62 (“Gladwin”) (para 80). Analysis and Conclusion [374] The Court has already concluded that the Income Funds were not a “mutu......
  • Gladwin Realty Corporation v. Canada, 2020 FCA 142
    • Canada
    • Court of Appeal (Canada)
    • September 14, 2020
    ...This is an appeal brought by The Gladwin Realty Corporation Inc. (Gladwin or the appellant) from a decision of the Tax Court of Canada (2019 TCC 62) wherein Hogan J. (the Tax Court judge) dismissed the appellant’s appeal from a Notice of determination issued by the Minister of National Reve......
  • 3295940 Canada Inc. v. The Queen, 2022 TCC 68
    • Canada
    • Tax Court (Canada)
    • June 30, 2022
    ...v. The Queen, [2011] 3 SCR 721 [Copthorne]). [76] Hogan, J., in paragraph 39 of the decision in The Gladwin Realty Corporation v. Canada, 2019 TCC 62 [Gladwin TCC], upheld by the Federal Court of Appeal, 2020 FCA 142 [Gladwin FCA], analyzed the provisions pertaining to the CDA, which is the......
  • Magren Holdings Ltd. v. The Queen, 2021 TCC 42
    • Canada
    • Tax Court (Canada)
    • April 1, 2022
    ...gain that was allocated by FMO to the Appellants. This conclusion should be addressed. [229] In Gladwin Realty Corporation v. The Queen, 2019 TCC 62 (“Gladwin”), the taxpayer had realized a taxable capital gain from the sale of a commercial real estate property and sought ......
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4 cases
  • Grenon v. The Queen, 2021 TCC 30
    • Canada
    • Tax Court (Canada)
    • June 1, 2021
    ...and disregard the one that was represented as being the real one” (para. 59). See also Gladwin Realty Corporation v. The Queen, 2019 TCC 62 (“Gladwin”) (para 80). Analysis and Conclusion [374] The Court has already concluded that the Income Funds were not a “mutu......
  • Gladwin Realty Corporation v. Canada, 2020 FCA 142
    • Canada
    • Court of Appeal (Canada)
    • September 14, 2020
    ...This is an appeal brought by The Gladwin Realty Corporation Inc. (Gladwin or the appellant) from a decision of the Tax Court of Canada (2019 TCC 62) wherein Hogan J. (the Tax Court judge) dismissed the appellant’s appeal from a Notice of determination issued by the Minister of National Reve......
  • 3295940 Canada Inc. v. The Queen, 2022 TCC 68
    • Canada
    • Tax Court (Canada)
    • June 30, 2022
    ...v. The Queen, [2011] 3 SCR 721 [Copthorne]). [76] Hogan, J., in paragraph 39 of the decision in The Gladwin Realty Corporation v. Canada, 2019 TCC 62 [Gladwin TCC], upheld by the Federal Court of Appeal, 2020 FCA 142 [Gladwin FCA], analyzed the provisions pertaining to the CDA, which is the......
  • Magren Holdings Ltd. v. The Queen, 2021 TCC 42
    • Canada
    • Tax Court (Canada)
    • April 1, 2022
    ...gain that was allocated by FMO to the Appellants. This conclusion should be addressed. [229] In Gladwin Realty Corporation v. The Queen, 2019 TCC 62 (“Gladwin”), the taxpayer had realized a taxable capital gain from the sale of a commercial real estate property and sought ......
2 firm's commentaries
  • What's New In Tax Controversy And Litigation?
    • Canada
    • Mondaq Canada
    • June 3, 2019
    ...S.A., 2007 FCA 236; Prévost Car Inc. v. Canada, 2009 FCA 57; Velcro Canada Inc. v. The Queen, 2012 TCC 57, respectively. 8 2018 TCC 182. 9 2019 TCC 62. 10 2018 TCC 11 2019 FC 377. The content of this article is intended to provide a general guide to the subject matter. Specialist advice sho......
  • FCA Confirms GAAR Applies To Limited Partner Capital Dividend Tax Plan
    • Canada
    • Mondaq Canada
    • October 12, 2020
    ...1. Gladwin Realty Corporation v The Queen, 2020 FCA 142 [Gladwin Realty (FCA)]. See also Gladwin Realty Corporation v The Queen, 2019 TCC 62. 2. Canada Trustco Mortgage Co. v 2005 SCC 54 . 3. 1245959 Alberta Ltd. v. Canada (Attorney General), 2018 FCA 114 . 4. Gladwin Realty (FCA) at pa......

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