Birchcliff Energy Ltd. v. The Queen, 2017 TCC 234
| Jurisdiction | Federal Jurisdiction (Canada) |
| Citation | 2017 TCC 234 |
| Court | Tax Court (Canada) |
| Date | 24 November 2017 |
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3 practice notes
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MMV Capital Partners Inc. v. The Queen, 2020 TCC 82
...Department of Finance, 1997). [10] OSFC Holdings, supra note 8 at paragraph 91. [11] Birchcliffe Energy Ltd. v. HMQ, 2015 TCC 232 [#1] and 2017 TCC 234 [#2]. [12] Canada Revenue Agency, Document 2003 - 0031823, "Transfer of a business by a shareholder" [2003] Ruling. [13] Mathew, ......
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Supreme Court Of Canada Won't Reconsider The GAAR In Birchcliff Energy Ltd.
...reverse takeover. It is also another missed opportunity for the Supreme Court to reconsider the GAAR. Footnotes 1 Birchcliff (2019 FCA) 2 2017 TCC 234 [Birchcliff (2017 TCC)] 3 RSC 1985 c. 1 (5th Supp.). 4 2015 TCC 232 5 Birchcliff (2019 FCA) at para. 32. 6 Birchcliff (2019 FCA) at para. 48......
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Birchcliff Energy Ltd. v. Canada, 2019 FCA 151
...THE QUEEN Respondent REASONS FOR JUDGMENT WEBB J.A. [1] This is an appeal from the judgment of Justice Jorré of the Tax Court of Canada (2017 TCC 234). The Tax Court dismissed the appeal of Birchcliff Energy Ltd. (Birchcliff) from the reassessment of its 2006 taxation year under the Income......
2 cases
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MMV Capital Partners Inc. v. The Queen, 2020 TCC 82
...Department of Finance, 1997). [10] OSFC Holdings, supra note 8 at paragraph 91. [11] Birchcliffe Energy Ltd. v. HMQ, 2015 TCC 232 [#1] and 2017 TCC 234 [#2]. [12] Canada Revenue Agency, Document 2003 - 0031823, "Transfer of a business by a shareholder" [2003] Ruling. [13] Mathew, ......
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Birchcliff Energy Ltd. v. Canada, 2019 FCA 151
...THE QUEEN Respondent REASONS FOR JUDGMENT WEBB J.A. [1] This is an appeal from the judgment of Justice Jorré of the Tax Court of Canada (2017 TCC 234). The Tax Court dismissed the appeal of Birchcliff Energy Ltd. (Birchcliff) from the reassessment of its 2006 taxation year under the Income......
1 firm's commentaries
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Supreme Court Of Canada Won't Reconsider The GAAR In Birchcliff Energy Ltd.
...reverse takeover. It is also another missed opportunity for the Supreme Court to reconsider the GAAR. Footnotes 1 Birchcliff (2019 FCA) 2 2017 TCC 234 [Birchcliff (2017 TCC)] 3 RSC 1985 c. 1 (5th Supp.). 4 2015 TCC 232 5 Birchcliff (2019 FCA) at para. 32. 6 Birchcliff (2019 FCA) at para. 48......