The Bank of Montreal v. The Queen, 2018 TCC 187
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2018 TCC 187 |
| Date | 12 September 2018 |
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5 practice notes
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Madison Pacific Properties Inc. v. The King, 2023 TCC 180
...alternative transactions as part of my tax benefit analysis. This is the same approach that I took in Bank of Montreal v. The Queen (2018 TCC 187 [upheld on appeal, 2020 FCA [17] Duha Printers (Western) Ltd. v. Canada, [1998] 1 S.C.R. 795, 159 D.L.R. (4th) 457. [18] Silicon Graphics Ltd. v.......
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Canadian Imperial Bank of Commerce v. The Queen,
...8 (CTC). [40] Sullivan, pages 40 and 41. [41] Canada Trustco, paragraph 12. [42] Sullivan, page 326. [43] The Bank of Montreal v. R., 2018 TCC 187. Section 3 of the Currency Act. The Canadian dollar has been the only legal tender in Canada since the enactment of the Uniform Currency Act in ......
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Canada v. Bank of Montreal, 2020 FCA 82
...FOR JUDGMENT WEBB J.A. [1] This is an appeal from the Judgment rendered by Graham J. of the Tax Court of Canada on September 12, 2018 (2018 TCC 187). The Tax Court Judge found that there was no tax benefit for the purposes of section 245 of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ......
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What's New In Tax Controversy And Litigation?
...1 2017 TCC 157. 2 Canada v. MacDonald, 2018 FCA 128. 3 2018 ONCA 562. 4 All statutory references are to the Income Tax Act. 5 2018 TCC 187. 6 2018 TCC 7 Canada v. MIL (Investments) S.A., 2007 FCA 236; Prévost Car Inc. v. Canada, 2009 FCA 57; Velcro Canada Inc. v. The Queen, 2012 TCC 57, res......
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4 cases
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Madison Pacific Properties Inc. v. The King, 2023 TCC 180
...alternative transactions as part of my tax benefit analysis. This is the same approach that I took in Bank of Montreal v. The Queen (2018 TCC 187 [upheld on appeal, 2020 FCA [17] Duha Printers (Western) Ltd. v. Canada, [1998] 1 S.C.R. 795, 159 D.L.R. (4th) 457. [18] Silicon Graphics Ltd. v.......
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Canadian Imperial Bank of Commerce v. The Queen,
...8 (CTC). [40] Sullivan, pages 40 and 41. [41] Canada Trustco, paragraph 12. [42] Sullivan, page 326. [43] The Bank of Montreal v. R., 2018 TCC 187. Section 3 of the Currency Act. The Canadian dollar has been the only legal tender in Canada since the enactment of the Uniform Currency Act in ......
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Canada v. Bank of Montreal, 2020 FCA 82
...FOR JUDGMENT WEBB J.A. [1] This is an appeal from the Judgment rendered by Graham J. of the Tax Court of Canada on September 12, 2018 (2018 TCC 187). The Tax Court Judge found that there was no tax benefit for the purposes of section 245 of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ......
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Bank of Montreal v. The Queen, 2021 TCC 3
...Firm: Torys LLP Toronto, Ontario For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada [1] 2018 TCC 187. [2] 2020 FCA 82. [3] As the parties have agreed to these points, I have not considered them. [4] Schedule II, Tariff B of the Tax Court of Canada......
1 firm's commentaries
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What's New In Tax Controversy And Litigation?
...1 2017 TCC 157. 2 Canada v. MacDonald, 2018 FCA 128. 3 2018 ONCA 562. 4 All statutory references are to the Income Tax Act. 5 2018 TCC 187. 6 2018 TCC 7 Canada v. MIL (Investments) S.A., 2007 FCA 236; Prévost Car Inc. v. Canada, 2009 FCA 57; Velcro Canada Inc. v. The Queen, 2012 TCC 57, res......