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II.   Background [2]   On February 4, 2010, the Applicant incorporated Vixen Salon & Beauty Bar Ltd. ... Those divisions include the ITA ’s objection and appeal procedures, which “constitute a complete appeal procedure that allows taxpayers to raise in the Tax Court all issues relating to the correctness of the assessments” (JP Morgan at para 82). [28]   Applicants cannot argue that a failure to consider a notice of objection that was not filed on a timely basis takes this matter out of the statutory scheme contained in the ITA and out of the specialized expertise of the Tax Court (Canada (National Revenue) v ConocoPhillips Canada Resources Corp, 2014 FCA 297 at para 10). [29]   As the Supreme Court of Canada stated in Addison at paragraph 11: Reviewing courts should be very cautious in authorizing judicial review in such circumstances. ... Manson" Judge   FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-882-17   STYLE OF CAUSE: ASHLEY ELIZABETH NEWTON v THE MINISTER OF NATIONAL REVENUE   PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: march 26, 2018   JUDGMENT AND reasons: MANSON J.   ...

GCKey assists over 30 Government departments, including ESDC; Parks Canada; Immigration, Refugees and Citizenship Canada; Natural Resources Canada; and the Royal Canadian Mounted Police, in controlling access to over 100 Enabled Services. ... The plaintiff must also show proximity — that the defendant was in a close and direct relationship to him or her such that it is just to impose a duty of care in the circumstances. ... As explained in Alberta v Elder Advocates of Alberta, 2011 SCC 24 at paragraph 74, the possibility of unlimited government liability to an unlimited class may tax public resources and chill governmental intervention. ...

Section 3(1)(b) of the EIPA has become an equally applicable purpose, as placing logs on the ECL “ensures that any action taken to promote the further processing in Canada of a natural resource that is produced in Canada is not rendered ineffective by reason of the unrestricted exportation of that natural resource”.  ...     [9]                According to the non-contradicted affidavit of Mrs. ...     [13]            At its February 1, 2008 meeting FTEAC considered Kemp’s request.  ...

If the essential nature of the taxpayer’s claim is a challenge to the assessment issued by the Minister, it can only be dealt with by the Tax Court of Canada (Canada v Addison & Leyen Ltd, 2007 SCC 33 [Addison & Leyen]). ... The refusal to reassess tax is not a matter that can be appealed to the Tax Court of Canada (Revera at para 13, citing Abakhan & Associates Inc v Canada (Attorney General), 2007 FC 1327). ... It serves an important public interest in seeking finality to decision-making, to the benefit of both the decision-maker and the party affected by the decision (Canada (Minister of Human Resources) v Hogervost, 2007 FCA 41 at paras 21 and 24; 396491 Canada Inc v Canada, 2020 FC 894 at para 39). ...

The process provided for an independent, expedited and fair hearing of CCRA human resources complaints. [5]                The ITPR hearing was lengthy and the process it adopted was quite formal or court-like. ... Given that potential, it would be a better use of judicial resources and it would facilitate a more coherent approach to have all of the review issues heard at one time at the end and with the benefit of the complete record, including the final Board decision. [20]            I also do not believe that an agreement by the parties not to raise the issue of prematurity is binding upon me in the exercise of my judicial review discretion. ... " R. L. Barnes "                                                                                                     J udge FEDERAL COURT NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET:                                           T-1743-04 STYLE OF CAUSE:                         CANADA CUSTOMS AND REVENUE AGENCY                                                             and                                                             PROFESSIONAL INSTITUTE OF THE PUBLIC                                                                             SERVICE OF CANADA PLACE OF HEARING:                     Toronto, Ontario DATE OF HEARING:                       February 6, 2006 REASONS FOR ORDER AND ORDER:                                    THE HONOURABLE MR JUSTICE BARNES DATED:                                              February 13, 2006 APPEARANCES: Mr. ...

Canada, docket T-2529-88 Date: 20001110 Docket: T-2529-88 & T-2214-90 BETWEEN:      ARCORP INVESTMENTS LTD.      Plaintiff     - and-      HER MAJESTY THE QUEEN      Defendant      REASONS FOR ORDER LEMIEUX J.: INTRODUCTION [1]      Arcorp Investments Ltd. ... Obviously, factors such as the frequency of the transactions, the duration of the holdings (whether, for instance, it is for a quick profit or a long-term investment), the intention to acquire for resale at a profit, the nature and quantity of the securities held or made the subject-matter of the transaction, the time spent on the activity, are all relevant and helpful factors in determining whether one has embarked upon a trading or dealing business. [16]      During Arcorp's 1984 fiscal year: (1) its assets were almost exclusively in the form of marketable securities having a market value of $1,138,163 at year end; (2) it bought or sold 1,595,735 shares in 32 resource sector (mining and oil and gas) companies traded on the Vancouver Stock Exchange ("VSE") resulting in proceeds of disposition of $1,445,037.43 for a net gain of $592,594.79. [17]      During Arcorp's 1985 fiscal year: (1) again, its assets were almost exclusively in the form of marketable securities having a market value of $474,658 at year end; (2) it transacted in approximately 900,000 shares in 24 companies in the resource sector (some of whom were on the 1984 year end inventory) resulting in proceeds of disposition of $1,009,092.72 for a net gain of $316,192. [18]      The securities and their transactions as carried out by Arcorp had the following characteristics:      (1)      the number of the shares held by Arcorp in each resource sector company in its portfolio was substantial: for example, there were six resource companies in which Arcorp held in each over 100,000 shares in 1984;      (2)      for the most part, these shares were speculative penny stock shares often purchased by Mr. ...

He seeks judicial review of the decision of the Refugee Appeal Division (RAD) denying his appeal. [2]   For the reasons that follow, this judicial review is dismissed.   ... The RAD agreed with the RPD’s finding that the there was “insufficient evidence to establish that the agents of persecution would be motivated to expend time, energy and resources” tracking the Applicant down and that this finding was not based on speculation (Refugee Appeal Division’s Reasons and Decision at para 24 [RAD RD]). [8]   The RAD referred to the National Documentation Package (NDP) stating “in general, a person fearing state and non-state actors is likely to be able to internally relocate to another area of [sic] Albanian” (RAD RD at para 25). ... In particular, he takes issue with the RAD’s finding that there was “insufficient evidence to establish that the agents of persecution would be motivated to expend time, energy and resources” tracking him down. [13]   Mr. ...

(LES TABACS GALAXY)   Applicant   and   CANADA CUSTOMS AND REVENUE AGENCY   Respondent     REASONS FOR ORDER AND ORDER     [1]        The corporation 9101-9380 Québec Inc. ... These Regulations will require certain conditions to be met to obtain and maintain a licence or registration, including age and sufficient financial resources requirements, which will provide a more comprehensive but strengthened licensing framework. ...       (2) Subject to subsections (3) and (4), an applicant is eligible for a licence, other than a licence issued under section 22 of the Act, if     (2) Sous réserve des paragraphe (3) et (4), est admissible à une licence ou un agrément, autre que l ’ agrément délivré en vertu de l ’ article 22 de la Loi, le demandeur qui rempli les conditions suivantes :       (a) they are not the subject of a receivership in respect of their debts;     a) il ne fait pas l ’ objet d ’ une mise sous séquestre à l ’ égard de ses dettes;       (b) they have not, in the five years immediately before the date of the application,     b) dans les cinq ans précédant la date de la demande  :       (i) failed to comply with any Act of Parliament, other than the Act, or of the legislature of a province respecting the taxation of or controls on alcohol or tobacco products or any regulations made under it, or     i) il n ’ a pas omis de se confirmer à toute loi fédérale, autre que la Loi, ou provinciale – ou à leur règlements – portant sur la taxation ou la réglementation de l ’ alcool ou des produits du tabac,       (ii) acted to defraud Her Majesty;     (ii) il n ’ a pas agi dans le but de frauder Sa Majesté;       (c) in the case of an applicant who is an individual, they     c) dans le cas où il est un particulier, il est :       (i) are at least eighteen years of age, and     (i) âgé d ’ au moins dix‑huit ans,       (ii) have sufficient financial resources to conduct their business in a responsible manner;            (ii) dispose des ressources financières suffisantes pour gérer son entreprise d ’ une manière responsable;(d) in the case of an applicant that is a partnership or unincorporated body,     d) dans le cas où il est une société de personnes ou un organisme non doté de la personnalité morale :       (i) where the partnership or unincorporated body is composed only of individuals, each of the individuals meets the requirement of subparagraph (c)(i) and the partnership or unincorporated body meets the requirement of subparagraph (c)(ii),     (i) s ’ il est composé uniquement de particuliers, ceux‑ci remplissent chacun la condition visée au sous‑alinéa c)(i) et le demandeur remplit la condition visée au sous‑alinéa c)(ii),       (ii) where the partnership or unincorporated body is composed only of corporations, each of the corporations meets the requirement of subparagraph (c)(ii), and     (ii) s ’ il est composé uniquement de personnes morales, celles‑ci remplissent chacune la condition visée au sous‑alinéa c)(ii),       (iii) where the partnership or unincorporated body is composed of both individuals and corporations, each of the individuals meets the requirement of subparagraph (c)(i) and the partnership or unincorporated body and each of the corporations meet the requirement of subparagraph (c)(ii); and     (iii) s ’ il est composé à la fois de particuliers et de personnes morales, les particuliers remplissent chacun la condition visée au sous‑alinéa c)(i) et le demandeur ainsi que les personnes morales qui le composent remplissent chacun la condition visée au sous‑alinéa c)(ii);       (e) in the case of an applicant that is a corporation, the corporation meets the requirement of subparagraph (c)(ii). ...

As such, it would not be an efficient use of judicial resources to grant an extension of time. [43] Furthermore, I am mindful that time limits exist in the public interest to bring finality to administrative decisions: Canada v Berhad, 2005 FCA 267 at para 60; Cossy v Canada Post Corporation, 2021 FC 559 at para 21; Lesly at para 18. ... Turley” Judge   FEDERAL COURT SOLICITORS OF RECORD DOCKET: 25-T-57   STYLE OF CAUSE: MICHAEL WETERINGS v THE ATTORNEY GENERAL OF CANADA   MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO, PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES, SOR/98-106   judgment and reasons: TURLEY J.   DATED: jUNE 13, 2025   WRITTEN REPRESENTATIONS BY: Michael J. Weterings   For The Applicant ON HIS OWN BEHALF   Jennifer Rogers   For The Respondent   SOLICITORS OF RECORD: Attorney General of Canada Vancouver, British Columbia   FOR THE RESPONDENT     ...

  [14]   I note that Justice Judith M. Woods, then a member of the Tax Court of Canada, came to a similar conclusion in Letendre v The Queen, 2011 TCC 577 at paragraph 10. ... JUDGMENT in T-367-16 THE COURT’S JUDGMENT is that: 1.   The application for judicial review is dismissed; 2.   ... DATED: MAY 10, 2019 APPEARANCES: Sofia Guedez Chantal Donaldson   FOR THE APPLICANT   Dominik Longchmaps Charles Camirand   FOR THE RESPONDENT   SOLICITORS OF RECORD: Donaldson Boissonneault Counsel Gatineau, Quebec   FOR THE APPLICANT   Attorney General of Canada Ottawa, Ontario   FOR THE RESPONDENT     ...