NRT Technology Corp. v. Canada
Source text
NRT Technology Corp. v. Canada Court (s) Database Federal Court of Appeal Decisions Date 2013-09-19 Neutral citation 2013 FCA 221 File numbers A-553-12 Decision Content Date: 20130919 Docket: A-553-12 Citation: 2013 FCA 221 CORAM: SHARLOW J.A. STRATAS J.A. NEAR J.A. BETWEEN: NRT TECHNOLOGY CORP. Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on September 19, 2013. Judgment delivered from the Bench at Toronto, Ontario, on September 19, 2013. REASONS FOR JUDGMENT OF THE COURT BY: SHARLOW J.A. Date: 20130919 Docket: A-553-12 Citation: 2013 FCA 221 CORAM: SHARLOW J.A. STRATAS J.A. NEAR J.A. BETWEEN: NRT TECHNOLOGY CORP. Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on September 19, 2013) SHARLOW J.A. [1] This is an appeal of a judgment of Justice Campbell Miller of the Tax Court of Canada dismissing an appeal of a reassessment under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) for the 2007 taxation year (2012 TCC 420). The issue is whether the appellant, NRT Technology Corp., Page: 3 is entitled to a deduction for certain pre-2007 non-capital losses of a corporation it acquired in 2006 with which it was subsequently amalgamated. [2] Despite the able submissions of counsel for NRT, we have been unable to discern any error of law or fact on the part of Justice Miller. [3] The appeal will be dismissed with costs. “K. Sharlow” J.A. FEDERAL COURT OF APPEAL NAMES OF COUNSEL…
Full judgment (source text)
Mirrored from decisions.fca-caf.gc.ca — the linked original is authoritative.
NRT Technology Corp. v. Canada Court (s) Database Federal Court of Appeal Decisions Date 2013-09-19 Neutral citation 2013 FCA 221 File numbers A-553-12 Decision Content Date: 20130919 Docket: A-553-12 Citation: 2013 FCA 221 CORAM: SHARLOW J.A. STRATAS J.A. NEAR J.A. BETWEEN: NRT TECHNOLOGY CORP. Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on September 19, 2013. Judgment delivered from the Bench at Toronto, Ontario, on September 19, 2013. REASONS FOR JUDGMENT OF THE COURT BY: SHARLOW J.A. Date: 20130919 Docket: A-553-12 Citation: 2013 FCA 221 CORAM: SHARLOW J.A. STRATAS J.A. NEAR J.A. BETWEEN: NRT TECHNOLOGY CORP. Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on September 19, 2013) SHARLOW J.A. [1] This is an appeal of a judgment of Justice Campbell Miller of the Tax Court of Canada dismissing an appeal of a reassessment under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) for the 2007 taxation year (2012 TCC 420). The issue is whether the appellant, NRT Technology Corp., Page: 3 is entitled to a deduction for certain pre-2007 non-capital losses of a corporation it acquired in 2006 with which it was subsequently amalgamated. [2] Despite the able submissions of counsel for NRT, we have been unable to discern any error of law or fact on the part of Justice Miller. [3] The appeal will be dismissed with costs. “K. Sharlow” J.A. FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-553-12 APPEAL FROM AN ORDER OF THE HONOURABLE JUSTICE CAMPBELL J. MILLER OF THE TAX COURT OF CANADA DATED NOVEMBER 30, 2012, IN COURT FILE NO. 2010-1901 IT(G). DOCKET: A-553-12 STYLE OF CAUSE: NRT TECHNOLOGY CORP. v. HER MAJESTY THE QUEEN PLACE OF HEARING: TORONTO, ONTARIO DATE OF HEARING: SEPTEMBER 19, 2013 REASONS FOR JUDGMENT OF THE COURT BY: SHARLOW J.A. STRATAS J.A. NEAR J.A. DELIVERED FROM THE BENCH BY: SHARLOW J.A. APPEARANCES: David Chodikoff Tarsem Basraon FOR THE APPELLANT Rita Araujo Arnold Bornstein FOR THE RESPONDENT SOLICITORS OF RECORD: Miller Thompson LLP Toronto, Ontario FOR THE APPELLANT William F. Pentney Deputy Attorney General of Canada FOR THE RESPONDENT
Source: decisions.fca-caf.gc.ca
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