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FCA

European Staffing Inc. v. Canada (National Revenue), 2020 FCA 219

GLEASON J.A.     BETWEEN: EUROPEAN STAFFING INC. Appellant and THE MINISTER OF NATIONAL REVENUE Respondent Heard by online video conference hosted by the Registry on December 17, 2020. ... GLEASON J.A.     BETWEEN: EUROPEAN STAFFING INC. Appellant and THE MINISTER OF NATIONAL REVENUE Respondent REASONS FOR JUDGMENT RENNIE J.A. [1]   The appellant appeals from the judgment of the Tax Court of Canada (2019 TCC 59, per Hogan J.), dismissing appeals from determinations by the Minister of National Revenue. ... Drouin Deputy Attorney General of Canada For The Respondent   ...
FCA

Canada v. Bank of Montreal, 2020 FCA 82

MACTAVISH J.A.   BETWEEN:     HER MAJESTY THE QUEEN     Appellant     and     BANK OF MONTREAL     Respondent   Heard at Toronto, Ontario, on February 6, 2020. ... MACTAVISH J.A.   BETWEEN:     HER MAJESTY THE QUEEN     Appellant     and     BANK OF MONTREAL     Respondent   REASONS 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). ... V.   Analysis [26]   This case arises in the context of the application of the GAAR. ...
FCA

Dirani v. Canada, 2023 FCA 13

ROUSSEL J.A.     BETWEEN: WASSEEM DIRANI Appellant and HIS MAJESTY THE KING Respondent Heard at Ottawa, Ontario, on January 19, 2023. ... ROUSSEL J.A.     BETWEEN: WASSEEM DIRANI Appellant and HIS MAJESTY THE KING Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Ottawa, Ontario, on January 19, 2023). ... François Daigle Deputy Attorney General of Canada For The Respondent   ...
FCA

Iris Technologies Inc. v. Canada (National Revenue), 2022 FCA 39

MINISTER OF NATIONAL REVENUE   PLACE OF HEARING: HEARD BY ONLINE VIDEO CONFERENCE HOSTED BY THE REGISTRY   DATE OF HEARING: March 2, 2022   REASONS FOR JUDGMENT OF THE COURT BY: RENNIE J.A. ... LEBLANC J.A.   DELIVERED FROM THE BENCH BY: RENNIE J.A. APPEARANCES: Leigh Somerville Taylor Mireille Dahab For The Appellant Andrea Jackett / Katie Beahen Elizabeth Chasson / Natanz Bergeron Christopher Ware For The Respondent SOLICITORS OF RECORD: Leigh Somerville Taylor Professional Corporation Toronto, ON Dahab Law Markham, ON For The Appellant A. François Daigle Deputy Attorney General of Canada For The Respondent   ...
FCA

Sylvie Lavoie c. Canada (Ministre du Revenu National), docket A-640-99

Date: 20001221                                             Docket: A-640-99 CORAM:          DÉCARY LÉTOURNEAU NOËL, JJ.A. ... CONCURRING:                          NOËL J.A. DISSENTING REASONS:    DÉCARY J.A. ... CONCURRING:                                 Noël J.A. DISSENTING REASONS BY:            Décary J.A. ...
FCA

Osadchuk v. Canada, 2023 FCA 82

ROUSSEL J.A.     BETWEEN: BRANDON OSADCHUK Appellant and HIS MAJESTY THE KING Respondent Heard at Edmonton, Alberta, on April 20, 2023. ... REASONS FOR JUDGMENT OF THE COURT BY: LOCKE J.A.   Date: 20230420 Docket: A-270-21 Citation: 2023 FCA 82 CORAM: LOCKE J.A. ... ROUSSEL J.A.     BETWEEN: BRANDON OSADCHUK Appellant and HIS MAJESTY THE KING Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Edmonton, Alberta, on April 20, 2023). ...
FCA

Canadian Magen David Adom for Israel v. Canada (Minister of National Revenue), 2002 DTC 7353, 2002 FCA 323

As a result of the meeting, it was decided that the CCRA would defer the revocation of CAMDI's status as a registered charity as long as CAMDI could meet the following conditions: ‚             establish that it had not gifted its resources to non-qualified donees; ‚             implement an agency agreement which would allow it to maintain effective direction and actual control over its resources and the programs undertaken on its behalf; ‚             carry out exclusively charitable activities; ‚             not have its activities carried out in the Occupied Territories; ‚             not have its resources used in the Occupied Territories; and, ‚             respect all the other requirements of the Act as they pertain to registered charities. [...] [63]            The letter then refers to the appellant's letter of July 6, 1999 and the enclosed list that indicated that an ambulance had been "given to the I.D.F. ... "Marshall Rothstein"                                                                                                                                                               J.A.                           ... Pascal Tétrault SOLICITORS OF RECORD: Drache, Burke-Robertson & Buchmayer LLP    FOR THE APPELLANT Morris A. ...
FCA

Canada (Attorney General) v. Oshkosh Defense Canada Inc., 2018 FCA 102

E.   Disposition of the motions [48]   An order shall issue in accordance with these reasons. ... DATED: May 30, 2018   WRITTEN REPRESENTATIONS BY: Derek Rasmussen Alexandre Kaufman   For The Applicant   Gerry Stobo March McLaren-Caus Cynthia Wallace   For The Respondent, oshkosh defense canada inc.   ... Drouin Deputy Attorney General of Canada   For The Applicant   Cassidy Levy Kent (Canada) LLP Ottawa, Ontario   For The Respondent, oshkosh defense canada inc.   ...
FCA

Canada v. Agnico-Eagle Mines Limited, 2016 FCA 130

I.                    BACKGROUND [8]                The parties provided a Partially Agreed Statement of Facts to the Judge. ... Toutefois: […] [91]            If applicable, this definition may well have led me to conclude that the Repayment Amount was the “value” of the Common Shares issued upon the repayment of each Convertible Debenture. ... AGNICO-EAGLE MINES LIMITED     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: jANUARY 26, 2016   REASONS FOR JUDGMENT BY: RYER J.A.   ...
FCA

Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2021 FCA 62

MINISTER OF NATIONAL REVENUE   PLACE OF HEARING: BY ONLINE VIDEOCONFERENCE     DATE OF HEARING: February 9, 2021     REASONS FOR JUDGMENT BY: RIVOALEN J.A.     ... LOCKE J.A.     DATED: MARCH 24, 2021     APPEARANCES: Nicolas X. Cloutier Samuel Julien   For the appellant   Pierre Lamothe Chantal Roberge Nancy Azzi   For the respondent   SOLICITORS OF RECORD: McCarthy Tétrault L.L.P. Montreal, Quebec   FOR THE APPELLANT   Nathalie G. Drouin Deputy Attorney General of Canada For the respondent     ...

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