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Justice O'Reilly     BETWEEN: IMPERIAL OIL RESOURCES LIMITED, IMPERIAL OIL RESOURCES VENTURES LIMITED Plaintiffs and   THE ATTORNEY GENERAL OF CANADA Defendant   REASONS FOR JUDGMENT AND JUDGMENT   I.  ... Where the context requires otherwise, I will refer to Imperial Oil Resources Limited as “IORL” and Imperial Oil Resources Ventures Limited as “IORVL” ... FEDERAL COURT   SOLICITORS OF RECORD       DOCKET:                                           T-1056-02   STYLE OF CAUSE:                           IMPERIAL OIL RESOURCES LIMITED, IMPERIAL OIL RESOURCES VENTURES LIMITED v. ...

SCOTT J.A.     Docket: A-413-14 BETWEEN: IMPERIAL OIL RESOURCES LIMITED Appellant and THE ATTORNEY GENERAL OF CANADA Respondent Docket: A-414-14 AND BETWEEN: IMPERIAL OIL RESOURCES VENTURES LIMITED Appellant and THE ATTORNEY GENERAL OF CANADA Respondent REASONS FOR JUDGMENT NOËL C.J. [1]                These are two appeals brought by Imperial Oil Resources Limited (IORL) and Imperial Oil Resources Ventures Limited (IORVL) (collectively, the appellants) from a decision of the Federal Court (2014 FC 839) wherein Gagné J. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-413-14     STYLE OF CAUSE: IMPERIAL OIL RESOURCES LIMITED v. THE ATTORNEY GENERAL OF CANADA     AND DOCKET: A-414-14     STYLE OF CAUSE: IMPERIAL OIL RESOURCES VENTURES LIMITED v. ...

ExxonMobil Canada Resources Company v. The King, 2023 TCC 143 Docket: 2017-5069(IT)G BETWEEN: EXXONMOBIL CANADA RESOURCES COMPANY, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Russell” Russell J.   Citation: 2023 TCC 143 Date: 26092023 Docket: 2017-5069(IT)G BETWEEN: EXXONMOBIL CANADA RESOURCES COMPANY, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Russell” Russell J.   CITATION: 2023 TCC 143 COURT FILE NO.: 2017-5069(IT)G STYLE OF CAUSE: EXXONMOBIL CANADA RESOURCES COMPANY AND HIS MAJESTY THE KING PLACE OF HEARING: Ottawa, Ontario DATE OF HEARING: August 10, 2023 REASONS FOR ORDER BY: The Honourable Justice Bruce Russell DATE OF ORDER: September 26, 2023 APPEARANCES: Counsel for the Appellant: Jehad Haymour Counsel for the Respondent: Wendy Bridges COUNSEL OF RECORD: For the Appellant: Name: Jehad Haymour   Firm: Bennett Jones LLP For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   [1] Appellant’s submissions, para. 21 ...

Conocophillips Canada Resources Corp. v. Canada (National Revenue), 2014 DTC 5014 [at at 6598], 2013 FC 1192, rev'd supra Docket: T-1666-10   Date: 20131126   Citation: 2013 FC 1192 Calgary, Alberta, November 26, 2013 PRESENT:    The Honourable Mr. Justice Campbell       BETWEEN: CONOCOPHILLIPS CANADA RESOURCES CORP.   ... We advise that our position remains the same.   ConocoPhillips Canada Resources Corp.'s (Conoco) Notice of Reassessment for the year ending November 30, 2000, was produced and mailed on November 7, 2008. ...

Accordingly, I issued an Order dated November 27, 2019 granting the respondent leave to file the Amended Reply. [3]   The proposed amendments to the Reply with respect to the Burlington appeal deal with the application of paragraph 20(1)(e.1) of the Income Tax Act (the “Act ”), whether the amounts payable by Burlington to its parent Burlington Resources Inc. ... Astrazeneca Canada Inc., 2012 FC 559; aff’d 2013 FCA 77. [7]   Burlington Resources Finance Company v The Queen, 2015 TCC 71 at paragraph 57. [8]   The change in the terminology was made in accordance with Justice Hogan’s Order, where he directed the respondent to provide clarity as to the nature of her transfer pricing position. It did not have anything to do with the respondent’s 20(1)(e.1) position. [9]   Burlington Resources Finance Company v The Queen, 2015 TCC 71. [10]   Continental Bank Leasing Corp v R, [1993] 1 CTC 2306 at para 22. [11]   Andersen Consulting v R, [1997] FCJ No 1433 at paras 11 to 14. [12]   See the Transcript of Proceedings pp 59 to 62, Order of Justice Campbell in Burlington Resources Company v HMQ 2015 TCC pp 20-21. [13]   Canderel Ltd v R, [1993] 2 CTC 213. [14]   Canderel Ltd v R, [1993] 2 CTC 213. [15]   Continental Bank Leasing Corp v R, [1993] 1 CTC 2306. [16]   Transcript of Refusals Motion, appellant’s Motion Record at tab R. [17]   Burlington Resources Finance Co v R, 2015 TCC 71 and Burlington Resources Finance Co v R., 2017 TCC 144. [18]   The only Replies filed with the Court were the initial Reply dated October 9, 2012 and the Further Amended Reply dated September 13, 2013. [19]   Cameco Corporation v The Queen, 2018 TCC 195. [20]   Teva Canada Limited v. ...

Burlington Resources Finance Company v. The Queen, 2013 DTC 1190, 2013 TCC 231       Docket: 2012-2683(IT)G BETWEEN: BURLINGTON RESOURCES FINANCE COMPANY, appellant, and   HER MAJESTY THE QUEEN, respondent.  ____________________________________________________________________ Motions heard on April 30, 2013, at Calgary, Alberta.   ... Hogan” Hogan J.           Citation: 2013 TCC 231 Date: 20130717 Docket: 2012-2683(IT)G BETWEEN: BURLINGTON RESOURCES FINANCE COMPANY, appellant, and   HER MAJESTY THE QUEEN, respondent.   REASONS FOR ORDER   Hogan J. I      Overview   [1]              In 2001 and 2002, Burlington Resources Finance Company (the “appellant” or “BRFC”), a Nova Scotia unlimited liability company (“NSULC”), borrowed approximately US $3 billion by issuing seven bonds (the “Notes”) guaranteed by Burlington Resources Inc. ...

Bp Canada Energy Resources Company v. The Queen, docket 2000-5160-IT-G 2000-5160(IT)G BETWEEN: BP CANADA ENERGY RESOURCES COMPANY AS SUCCESSOR TO AMOCO CANADA RESOURCES LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Date: 20021016 Docket: 2000-5160(IT)G BETWEEN: BP CANADA ENERGY RESOURCES COMPANY AS SUCCESSOR TO AMOCO CANADA RESOURCES LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... The appellant says that if the receipt is income it represents resource income and qualifies for the resource allowance. [2]      The amounts were received as part of a "decontracting" arrangement between the appellant and A & S and PGT. ...

Imperial Oil Resources Limited v. Canada (Procureur général), 2014 FC 838 Date: 20140902 Docket: T-1382-06 Citation: 2014 FC 838 Ottawa, Ontario, September 2, 2014 PRESENT:    The Honourable Madam Justice Gagné BETWEEN: IMPERIAL OIL RESOURCES LIMITED Applicant and THE ATTORNEY GENERAL OF CANADA Respondent JUDGMENT AND REASONS Overview [1]                This is an application for judicial review brought by Imperial Oil Resources Limited [Imperial Oil] against the Attorney General of Canada, representing the Minister of National Revenue [Minister] relating to the Syncrude Remission Order, CRC, c 794 [SRO], an initiative undertaken in 1976 by the federal government to provide some federal tax relief to participants in the Syncrude (oil sands) project in northern Alberta. ... [ITA] is correctness, as it is a question of law (Canada (Attorney General) v Imperial Oil Resources Limited, 2009 FCA 325 [Imperial Oil] at para 2). ... "Jocelyne Gagné" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1382-06   STYLE OF CAUSE: IMPERIAL OIL RESOURCES LIMITED v THE ATTORNEY GENERAL OF CANADA   PLACE OF HEARING: Calgary, Alberta   DATE OF HEARING: June 4, 2014   JUDGMENT AND REASONS: GAGNÉ J.   ...

Burlington Resources Finance Company v. The Queen, 2017 TCC 144  Docket: 2012-2683(IT)G BETWEEN: BURLINGTON RESOURCES FINANCE COMPANY, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... (“BRCL”); Burlington Resources Canada Inc. (“BRCI”), which was predecessor to BRCL Burlington Resources Canada (Hunter) Ltd. ... (“BRCEL”), Poco Petroleum, Burlington Resources Canada Partnership, BR (Global Holdings) BV, Burlington Resources Capital, and Burlington Resources Capital II (collectively, the “Named Guarantees”). ...

Human Resources, 2008 TCC 213     Docket: 2007-4090(OAS)   BETWEEN: YVON PARIS, Appellant, and   THE MINISTER OF SOCIAL DEVELOPMENT, Respondent. ...   [12]     In closing, I believe that a consultation with a resource person would provide the Appellants with the benefit of a straightforward and accessible explanation of the requirements and consequences of the relevant provisions of the Act ... Signed at Ottawa, Canada, this 16th day of April 2008.       "Alain Tardif" Tardif J.               ...