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FCTD
Benoit v. Canada, 2002 FCT 243
Beaulieu received his Doctorate in History from the Université Laval in 1993. ... Levogiannis, [1993] 4 S.C.R. 475, at p. 487). Rather, they are animated by broad, flexible principles, applied purposively to promote truth-finding and fairness. ...
TCC
Cassan v. The Queen, 2017 TCC 174
Beblow [1993] 1 S.C.R. 980, at p. 991-92, “the central element of a gift [is the] intentional giving to another without expectation of remuneration”. [24] The essential ingredients of a legally valid gift are not in dispute. ... Beblow, [1993] 1 S.C.R. 980 (“ Beblow ”), Thorsteinson Estate v. Olson, 2016 SKCA 134, St. ...
TCC
Grenon v. The Queen, 2021 TCC 30
For the same reason, there was not a lawful distribution pursuant subparagraph (1)(d.2)(ii) of Regulation 4900. [48] It has been noted that this provision has very little practical application today since it was introduced as a retroactive relieving measure in 2001 for units of certain mutual funds sold by private placement between 1993 and 1999. [345] As a result, the Court must reject this argument in its entirety. l) Conclusion [346] In the end, it is difficult for the Court to disagree with the Respondent’s suggestion that the Appellant has demonstrated a wanton and reckless disregard for the requirements of the securities legislation, the OME and the OM. [347] Without going that far, I would at least conclude that the Appellant was careless, cavalier and possibly indifferent. ... Canada (1993) FCJ No. 740 (FCA), 2 C.T.C. 257 (“ Smith ”), the issue was the extent to which a taxpayer had to be involved in the attribution of a benefit to a third party to engage subsection 56(2). ...
TCC
Drouin v. The Queen, 2014 DTC 1016 [at at 2564], 2013 TCC 139
Canada, [1993] 4 S.C.R. 695. These standards or objective factors, which were listed by Justice Dickson in Moldowan, supra, make it possible to make an "overall assessment. . . whether or not the taxpayer is carrying on the activity in a commercial manner" (paragraph 55 of Stewart). ...
TCC
Blackmore v. The Queen, 2013 DTC 1213 [at at 1147], 2013 TCC 264, aff'd 2014 DTC 5123 [at 7316], 2014 FCA 210
. … (R. v Morgentaler, [1993] 3 S.C.R. 463, at p. 484) [35] Pierre-André Côté in The Interpretation of Legislation in Canada, (4th ed., Carswell, 2011), at pp. 465-466, summarizes this view as follows: Approaching the question from the perspective of weight rather than admissibility, a choice unanimously approved by doctrine, side-steps the often sterile debate on admissibility and enables the courts to access information that allows them to render more enlightened decisions, while preserving their right to determine the weight to be given to such information. ...
TCC
Husky Energy Inc. v. The King, 2023 TCC 167
Norman, [1993] O.J. No. 2802 (QL), 68 O.A.C. 22, the Court of Appeal for Ontario explained the importance of reliability at paragraph 47:... ...
TCC
Gill v. M.N.R., 2006 TCC 149
By 1998, the irrigation system was working satisfactorily but as early as 1993, a pipe – one to one and one-half inch in diameter – carried water directly to the roots of plants and was dispersed – drop by drop – through a series of drippers. ...