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FCA
Vo v. Canada, 2015 FCA 246
RENNIE J.A. BETWEEN: QUYNH VO Appellant And HER MAJESTY THE QUEEN Respondent Heard at Calgary, Alberta, on November 4, 2015. ... REASONS FOR JUDGMENT OF THE COURT BY: RYER J.A. Date: 20151104 Docket: A-140-14 Citation: 2015 FCA 246 CORAM: RYER J.A. ... Pentney Deputy Attorney General of Canada Ottawa, Ontario For The Respondent ...
FCA
Klundert v. Canada, 2017 FCA 134
His appeal of these assessments was not successful. [3] Prior to May 18, 1994, Dr. ... Klundert transferred property to her by directing OHIP to make these deposits. [6] The liability of Ann Klundert under paragraph 160(1)(e) of the ITA is limited to the lesser of: (a) The amount by which the fair market value of the property transferred to her exceeds the consideration given by her for the property; and (b) The total liability of Dr. ... Pentney Deputy Attorney General of Canada For The Respondent ...
FCA
Revcon Oilfield Constructions Incorporated v. Canada (National Revenue), 2017 FCA 22
Thompson, 2016 SCC 21, [2016] 1 S.C.R. 381. [6] We reject the appellant’s new argument. ... It says that the Federal Court’s order is an order against its law firm. [9] We disagree. ... Pentney Deputy Attorney General of Canada Edmonton, Alberta For The Respondent ...
FCA
Salloum v. Canada, 2016 FCA 85
REASONS FOR JUDGMENT OF THE COURT BY: RYER J.A. Date: 20160314 Docket: A-9-15 Citation: 2016 FCA 85 CORAM: RYER J.A. ... This we cannot do. [9] Accordingly, the appeal will be dismissed without costs. ... Pentney Deputy Attorney General of Canada Ottawa, Ontario For The Respondent ...
FCA
Helgesen v. Canada, 2017 FCA 21
REASONS FOR JUDGMENT OF THE COURT BY: SCOTT J.A. Date: 20170201 Docket: A-177-16 Citation: 2017 FCA 21 CORAM: STRATAS J.A. ... SCOTT J.A. [1] In reasons cited as 2016 TCC 114, Ouimet J. ... Pentney Deputy Attorney General of Canada Edmonton, Alberta For The Respondent ...
FCA
Canadian Clyde Tube Forgings Ltd. v. The Queen, 82 DTC 6041, [1982] CTC 21 (FCA)
The parties agreed that the formula is MP = q = ML x Adjusted business income for this purpose, the initials mean: MP: Canadian Manufacturing and Processing Profits ML: Cost of Manufacturing and Processing Labour L: Cost of Labour C: Cost of Capital The parties agree on the amounts of all items to be used in the formula for purposes of this case except the “Cost of Labour” and “Cost of Manufacturing and Processing Labour”. ...
FCA
Canadian Imperial Bank of Commerce v. Canada, 2023 FCA 91
GOYETTE J.A. BETWEEN: CANADIAN IMPERIAL BANK OF COMMERCE Appellant and HIS MAJESTY THE KING Respondent Heard at Toronto, Ontario, on December 13, 2022. ... GOYETTE J.A. Date: 20230504 Docket: A-305-21 Citation: 2023 FCA 91 CORAM: WEBB J.A. ... HIS MAJESTY THE KING PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: December 13, 2022 REASONS FOR JUDGMENT BY: WEBB J.A. ...
FCA
Chevron Canada Limited v. Minister of National Revenue, [1986] 2 CTC 495, 86 DTC 6595
Retail Outlets — Includes: (a) Dealer Operated Service Stations — these facilities are either owned or leased by Chevron or by the dealer. ... (b) Self-Service Stations — these facilities are usually owned by Chevron and operated by a Chevron agent. ... (c) Cardlock/Keylock — these are unattended facilities making sales to approved customers. ...
FCA
The Queen v. AEL Microtel Ltd., 86 DTC 6348, [1986] 2 CTC 108 (FCA)
That amount was calculated as follows: Approved capital cost: $1,173,000 x 20% — $234,600 Jobs to be created: $154.8 new jobs @ $1,500 — $232,200 Lenkurt also was paid a development incentive in the amount of $595,217 in respect of a new manufacturing facility at Winnipeg. That amount was calculated as follows: Approved capital cost: $1,628,752 x 25% — $407,188 Approved wages and salaries: $1,253,527 x 15% — $188,029 There is no significance for purposes of these appeals in the different approaches taken in the calculation of the “job creation" portions of the incentives as distinct from their “‘capital cost” portions. ...
FCA
Paletta International Corporation v. Canada, 2021 FCA 182
“Judith Woods” J.A. FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD Dockets: A-417-19 and A-418-19 DOCKET: A-417-19 STYLE OF CAUSE: PALETTA INTERNATIONAL CORPORATION v. HER MAJESTY THE QUEEN AND DOCKET: A-418-19 STYLE OF CAUSE: ANGELO PALETTA v. ... François Daigle Deputy Attorney General of Canada For The Respondent ...