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FCA
Dirani v. Canada, 2018 FCA 56
REASONS FOR JUDGMENT OF THE COURT BY: RENNIE J.A. Date: 20180321 Docket: A-123-16 Citation: 2018 FCA 56 CORAM: RENNIE J.A. ... DOCKET: A-123-16 STYLE OF CAUSE: WASSEEM DIRANI v. HER MAJESTY THE QUEEN PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: March 21, 2018 REASONS FOR JUDGMENT OF THE COURT BY: RENNIE J.A. ... Drouin Deputy Attorney General of Canada For The Respondent ...
FCA
Lanno v. Canada (Customs and Revenue Agency), 2006 FCA 220
REASONS FOR ORDER BY: SHARLOW J.A. Date: 20060614 Docket: A-478-04 Citation: 2006 FCA 220 Present: SHARLOW J.A. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-478-04 STYLE OF CAUSE: DENIS LANNO v. ...
FCA
Schachtschneider v. The Queen, 93 DTC 5298, [1993] 2 CTC 178 (FCA)
I am entirely rational & would not have married just to pay more income tax! ... Thus, more than “ miniscule”, “ trivial” or “insubstantial” effects are required for a Charter violation. ... As I have indicated, the ground of discrimination — marital status — should not be confused with the group claimin discrimination — married people. ...
FCA
Canada (National Revenue) v. CGI Holding LLC, 2016 FCA 286
NEAR J.A. Date: 20161116 Docket: A-550-15 Citation: 2016 FCA 286 CORAM: PELLETIER J.A. ... CGI HOLDING LLC PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: september 12, 2016 REASONS FOR JUDGMENT BY: WEBB J.A. ... Pentney Deputy Attorney General of Canada Toronto, Ontario For The Appellant McCarthy Tétrault LLP Barristers & Solicitors Toronto, Ontario For The Respondent ...
FCA
Bourque v. The Queen, 96 DTC 6412, [1996] 3 CTC 10 (FCA)
.: — The Appellant maintained horses which he raced. He argues that this resulted in his having two separate sources of business income: the maintenance of horses for racing and racing itself. Of these, only the former would fall within the extended definition of “farming” in section 248: 248(1) Definitions — In this Act,..“Farming” — “farming” includes tillage of the soil, livestock raising or exhibiting, maintaining of horses for racing, raising of poultry, fur farming, dairy farming, fruit growing and the keeping of bees, but does not include an office or employment under a person engaged in the business of farming; The Appellant’s argument cannot be reconciled with this Court’s decision in Juster v. ...
FCA
Foix v. Canada, 2023 FCA 38
LOCKE J.A. BETWEEN: MICHEL FOIX, NICOLAS SOUTY and SONIA LEBEL Appellants and HIS MAJESTY THE KING Respondent Heard at Montréal, Quebec, on October 20, 2022. ... LOCKE J.A. BETWEEN: MICHEL FOIX, NICOLAS SOUTY and SONIA LEBEL Appellants and HIS MAJESTY THE KING Respondent NOËL C.J. ... HIS MAJESTY THE KING PLACE OF HEARING: MONTRÉAL, QUEBEC DATE OF HEARING: OCTOBER 20, 2022 REASONS FOR JUDGMENT BY: NOËL C.J. ...
FCA
Roberto Aquilini et al. v. Her Majesty the Queen, 2021 FCA 206
Beginning in 2001, a reorganization was undertaken to consolidate the interests under one limited partnership – AIGLP. ... A fair reading of his reasons reflects the focus on the allocation of the income of AIGLP and the losses of the GERI partnership. [50] The only partners of the GERI partnership, as set out in paragraph 99 of the Partial Agreed Statement of Facts and Schedule “A” to that agreement, were: ● Elisa Aquilini ● Francesco Aquilini ● Roberto Aquilini ● Paolo Aquilini ● Global Coin Corporation ● Cranberry Plantation Inc. [51] None of the EAFT, the FAFT, the RAFT, or the PAFT were partners of the GERI partnership. ... François Daigle Deputy Attorney General of Canada For The Respondent ...
FCA
Buhler Versatile Inc. v. Canada, 2016 FCA 68
DEMONTIGNY J.A. BETWEEN: BUHLER VERSATILE INC. Appellant and HER MAJESTY THE QUEEN Respondent Heard at Winnipeg, Manitoba, on March 1, 2016. ... The Judge granted a motion brought by Her Majesty the Queen (the “Crown”), pursuant to Rules 95 and 110 of the Tax Court of Canada Rules (General Procedure), S.O.R./90-688a (the “ Tax Court Rules ”), for an order compelling Buhler Versatile Inc. ... Pentney Deputy Attorney General of Canada For The Respondent ...
FCA
Lloyd v. Canada (Attorney General), 2016 FCA 115
SCOTT J.A. Date: 20160413 Docket: A-368-15 Citation: 2016 FCA 115 CORAM: GAUTHIER J.A. ... The Notice of Disciplinary Action set out the reasons for imposing the suspension: 1. ... Pentney Deputy Attorney General of Canada Ottawa, Ontario For The Respondent ...
FCA
Timmins v. R., 99 DTC 5494, [1999] 2 CTC 133 (FCA)
[emphasis added] a) il a été employé par une personne qui était un employeur désigné, dans un but autre que celui de fournir des services en vertu d’un programme prescrit du gouvernement du Canada d’aide au développement international, et [...] ... [20] and Tonn v. /?., [21] he held that the Department did not have “a reasonable expectation of profit” when it entered into the contract. ... Tara Exploration & Development Co., (1970), 70 D.T.C. 6370 (Can. Ex. ...