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FCTD

M.C.A. Television Ltd. v. Canada, [1995] 1 CTC 321

Imperial Tobacco Ltd. (1993), 50 C.P.R. (3d) 59, 66 F.T.R. 148, page 65 (F.T.R. 152), where my colleague Rouleau J., following a patent trial, reported here by counsel for the defendant to have been an eight-day trial, and an appeal, in both of which the plaintiffs were successful, allowed increases over the amounts for services of counsel specified in Tariff B with respect to examinations for discovery, for preparation for trial, and for conduct of trial, the last at daily rates of $1,500 for senior counsel and $750 for junior counsel. ...
FCTD

Harrison v. Canada (National Revenue), 2020 FC 772

The Second Reassessment (December 29, 1993) made adjustments to her participation in Sierra Trinity. The Applicant filed the First Notice of Objection, in respect of the First Reassessment, on March 23, 1993. ... In the “Notice of Appeal” filed, the reassessment dated December 29, 1992 (“First Reassessment”) and the reassessment dated December 29, 1993 (“Second Reassessment”) are both acknowledged. ...
FCTD

Ludco Enterprises Ltd. v. Canada, docket T-742-93

These re-assessments were confirmed by a judgment of the Tax Court of Canada in 1993. 3 The plaintiffs bring these appeals from the Tax Court of Canada decision by way of a trial de novo. 4 By order of this Court, the four appeals were heard simultaneously and on the basis of common evidence and argument. [7]      The plaintiffs called four witnesses. ... The Queen (1993), 93 DTC 1004 (C.T.C.) at 1012, the earning of dividend income cannot be said to be the real purpose of the use of the borrowed funds. ... The relevant portions of section 20 are set out in the Schedule to these Reasons.      3      (1993), 93 DTC 1351.      4      The appeals are pursuant to section 172 of the Act and require a trial de novo: Minister of National Revenue v. ...
FCTD

Quebec (Attorney General) v. Canada, 2007 FC 826

  [28]     The hierarchy in the federal Department of Finance in 1993 was as follows: 1.     ... In 1993 he was in the department’s federal-provincial Financial Policy Branch responsible for preparing Quebec’s stabilization application (Exhibit P-1) and the amended application (Exhibit P-2). ... He testified on exchanges between the federal and Quebec teams at the meetings of June 15, 1993 and March 7 and September 12, 1994 ...
FCTD

Doig v. Canada, 2011 DTC5064 [at at 5725], 2011 FC 371

Doig was indebted to the Crown in the amount of $323,738.31, comprised of unpaid taxes, interest and penalties “from taxation years prior to and including 1982, 1983, 1984, 1985, 1986, 1987, 1988, 1989, 1991, 1992, and 1993.” ... the applicant received 21 “legal warnings” from CRA from June 22, 1989 to November 26, 1993 about the outstanding balance owed; and f.                     ...
FCTD

Scott Paper Ltd. v. Canada, 2005 FC 1354

The Plaintiff argued that facial tissues could be obtained on a tax exempt basis by persons who were included in the description of "manufacturer or producer" as described in subsection 2(1) of the Act and who were licensed under the Act during the relevant period. [7]                The Minister, by Notice of Determination dated September 21, 1993, disallowed the N15 Refund Claim on the basis that the Plaintiff's sales of facial tissue were correctly made on a tax- paid basis. No audit was performed by the Defendant to determine the amount potentially recoverable under the N15 Refund Claim. [8]                On December 9, 1993, the Plaintiff filed a Notice of Objection to the Notice of Determination, on the basis that, according to the decision of the Federal Court of Appeal in CIP, supra, facial tissues should be included in the definition of "cosmetics" pursuant to subsection 2(1) of the Act and should not be subject to FST by virtue of paragraph 50(5)(g), formerly paragraph 27(2)(g) of the Act. [9]                On March 14, 1995, the Plaintiff agreed to hold its N15 Refund Claim in abeyance pending resolution of a similar claim by one of its major competitors, Kimberly-Clark Canada Inc. ...
FCTD

Filenet Corp. v. The QueenL, 2001 FCT 865

FILENET was registered in 1989 for use in association with "computer hardware, software and peripherals; automated office systems for the storage retrieval, handling and processing of business documents". [5]                 In 1993, the Canada Custom and Revenue Agency (then the Department of National Revenue) instituted nationally a program entitled "EFILE" (in English), which permitted taxpayers to file their tax returns electronically. ... Henderson, Trade-marks Law of Canada (Toronto: Carswell, 1993), states at page 388: There is no provision in the Act for expunging, cancelling or otherwise annulling the effect of the publication of an official mark under subparagraph 9(1)(n)(iii), or any other publication which may be a condition precedent to the application of other paragraphs of the section. ...
FCTD

Ebco Industries Ltd. v. Canada, docket T-2519-90

Section 2(1) of the Excise Tax Act provides, in part, that a municipality includes, in addition to various obvious municipal bodies: (b) such other local authority as the Governor in Council may determine to be a municipality for the purposes of this Act; The 24 April 1986 determination is as follows: HER EXCELLENCY THE GOVERNOR GENERAL IN COUNCIL, on the recommendation of the Minister of National Revenue, pursuant to paragraph (b) of the definition of "municipality" in subsection (2(1) of the Excise Tax Act, is pleased hereby to determine the authority listed in the schedule hereto to be a municipality for the purposes of the Excise Tax Act. [8]      BC Transit, a crown corporation had, as of 12 August, 1982, been established by means of the BC Transit Act, R.S.B.C. 1979, ch. 421, as amended. 1 The parties have provided a copy of the Act as it existed 25 November, 1993. ... Hasselwander, [1993] 2 S.C.R. 398. If the ordinary meaning of the words is consistent with the context in which the words are used and with the object of the act, then that is the interpretation which should govern. [43]      To return to the Defendant"s submission, it is that Metro-Transit was a local authority but BC Transit is not a purely local authority, referring to the definition of a municipality in section 2(1) of the Excise Tax Act: "municipality" means      (a) an incorporated city, town, village, metropolitan authority, township, district, county or rural municipality or other incorporated municipal body however designated, or      (b) such other local authority as the Minister may determine to be a municipality for the purposes of this Act; [44]      I should begin by looking at the ordinary meaning of the phrase "local authority". ...
FCTD

Ticketnet Corp. v. Canada, docket T-2185-88

Div; Action No. 161251/86; February 10, 1993). [19]      Farley J. calculated Ticketnet"s gross loss at approximately $13.5 million, but in awarding damages against Air Canada, he deducted $2 million in respect of Ticketnet"s contractual liability to pay Air Canada, although the payment "had not yet become due": op. cit., paragraph 111. ... Canadian Commercial Bank, [1993] 3 S.C.R. 558 for the proposition that a transaction does not lose the character of a loan because it also includes provisions for the participation by the party advancing the money in the profits generated by the recipient. ...
FCTD

Sarji v. Canada (Minister of National Revenue - Customs & Excise), docket T-2468-93

(the "Act") appeals by way of action the decision of the Minister of National Revenue (the "Minister"), dated July 21, 1993, made under section 131 of the Act, confirming the forfeiture of seized jewellery on the grounds there had been a contravention of the Act or the Regulations. ... THE MINISTER'S DECISION (51     The Minister's decision is in the form of a letter to the plaintiff dated July 21, 1993 from J. ...

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