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Coastal Resources Limited v. Canada (National Revenue), 2009 FC 181   Date: 20090219 Docket: T-591-08 Citation: 2009 FC 181 Vancouver, British Columbia, February 19, 2009 PRESENT:     The Honourable Madam Justice Heneghan     BETWEEN: COASTAL RESOURCES LIMITED Applicant and   THE MINISTER OF NATIONAL REVENUE Respondent       REASONS FOR JUDGMENT AND JUDGMENT   [1]                Coastal Resources Limited (the “Applicant”) seeks judicial review of the decision of the Minister of National Revenue (the “Respondent”). ... Heneghan” Judge FEDERAL COURT   SOLICITORS OF RECORD       DOCKET:                                           T-591-08   STYLE OF CAUSE:                          COASTAL RESOURCES LIMITED                                                             v. ... DATED:                                              February 19, 2009       APPEARANCES:   Craig C. ...

Canada (Minister of Human Resources Development v. Heaman, 2004 FC 1155                                                                                                                                   Date: 20040819                                                                                                                                Docket: T-290-03                                                                                                                       Citation: 2004 FC 1155 OTTAWA, ONTARIO, THURSDAY, THIS 19 TH DAY OF AUGUST, 2004 PRESENT: THE HONOURABLE MADAM JUSTICE SNIDER BETWEEN:                             MINISTER OF HUMAN RESOURCES DEVELOPMENT                                                                                                                                             Applicant                                                                         - and-                                                             BERNICE HEAMAN                                                                                                                                         Respondent                                             REASONS FOR ORDER AND ORDER SNIDER J. [1]         Since February 1998, Ms. ... The Applicant, the Minister of Human Resources Development (the_ Minister_), took the position that the pay equity monies were a retroactive salary adjustment that should be included for purposes of calculating her Guaranteed Income Supplement (_ Supplement_). ... Snider_                                                                     Judge                                                              FEDERAL COURT                             NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET:                                          T-290-03 STYLE OF CAUSE:                          MINISTER OF HUMAN RESOURCES DEVELOPMENT v. ...

Imperial Oil Resources Ventures Limited v. Canada (Attorney General), 2014 DTC 5113 [at 7275], 2014 FC 839 Date: 20140902 Dockets:       T-1-05 T-2155-10 Citation: 2014 FC 839 Ottawa, Ontario, September 2, 2014 PRESENT:    The Honourable Madam Justice Gagné Docket: T-1-05 BETWEEN: IMPERIAL OIL RESOURCES LIMITED Applicant and THE ATTORNEY GENERAL OF CANADA Respondent Docket: T-2155-10 AND BETWEEN: IMPERIAL OIL RESOURCES VENTURES LIMITED Applicant and THE ATTORNEY GENERAL OF CANADA Respondent JUDGMENT AND REASONS Overview [1]                These are two applications for judicial review brought by Imperial Oil Resources Limited (file T-1-05) and Imperial Oil Resources Venture Limited (file T-2155-10) [collectively “Imperial Oil”] against 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. ... By the combined operation of those provisions, a resource producer, in computing its income for income tax purposes, was required to include and could not deduct any resource royalty payable to a province. [11]            During the period when the resource royalty amendments were being made to the ITA, the development of the oil sands in northern Alberta was in its beginning stages. ... "Jocelyne Gagné" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1-05   STYLE OF CAUSE: IMPERIAL OIL RESOURCES LIMITED v THE ATTORNEY GENERAL OF CANADA   AND DOCKET: T-2155-10   STYLE OF CAUSE: IMPERIAL OIL RESOURCES VENTURES LIMITED v THE ATTORNEY GENERAL OF CANADA   PLACE OF HEARING: Calgary, Alberta   DATE OF HEARING: June 3, 2014   JUDGMENT AND REASONS: GAGNÉ J.   ...

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. ...

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. ...

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.   ...

See, for example, Canada (Minister of Human Resources Development) v. ... See, for example, Canada (Minister of Human Resources and Development) v. ... "James Russell"                       JFC                                      FEDERAL COURT                                                           NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET:                  T-145-04 STYLE OF CAUSE: MINISTER OF HUMAN RESOURCES DEVELOPMENT v. ...

ConocoPhillips Canada Resources Corp. v. Canada (National Revenue), 2016 DTC 5016 [at 6588], 2016 FC 98, 2017 FCA 243 rev'd Date: 20160127 Docket: T-1811-12 Citation: 2016 FC 98 Ottawa, Ontario, January 27, 2016 PRESENT:   The Honourable Mr. Justice Boswell BETWEEN: CONOCOPHILLIPS CANADA RESOURCES CORP. Applicant and THE MINISTER OF NATIONAL REVENUE Respondent JUDGMENT AND REASONS I.   ... Boswell" Judge   FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1811-12   STYLE OF CAUSE: CONOCOPHILLIPS CANADA RESOURCES CORP. v THE MINISTER OF NATIONAL REVENUE   PLACE OF HEARING: Ottawa, Ontario   DATE OF HEARING: September 14, 2015   JUDGMENT AND REASONS: BOSWELL J.   ...

At all material times, Carter Oil & Gas Ltd. ("Carter") was a principalbusiness corporation as defined in paragraph 66(15)(h) of the Act. 3. ... On December 11, 1979, the plaintiff entered into an agreement with Carter Oil & Gas, whereby he purchased from Carter certain resource properties for the agreed price of $3,500,000. ... Under the terms of this agreement, Carter Oil & Gas was to act as agent for all those who had purchased the resource properties in handling all the finances, expenses, revenues and disbursing income. ...

The main issue was the manner of calculation of the applicant's resource profits and resource allowance ("the Resource Allowance Issue"). ... Gulf Canada Resources Ltd., 1992 DTC 6123 (FCA) which dealt with the Resource Allowance Issue. ... The present application for judicial review is denied with costs in favour of the respondent.      ...