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FCTD

Prodor v. R., [1997] 3 C.T.C. 179, 97 D.T.C. 5472

Accordingly, the certificates were registered in the New Westminster Land Title Office in the Province of British Columbia as judgments against the Plaintiff's interest as mortgagee in a particular mortgage registered in the said land title office under number Y56792 as follows: a) the certified amount of $249,729.88 was registered against the Mortgage on June 21, 1990 and renewed on May 12, 1992; b) the certified amount of $45,211.84 was registered against the Mortgage on May 12, 1992; and c) the certified amount of $137,191.48 was registered against the Mortgage on December 7, 1990 and renewed on November 5, 1992. 3 The Plaintiff was advised by officers of the Defendant, the Minister of National Revenue, that he owed a total amount of $533,566.28 as of March 9, 1993 in respect of the original amounts payable which were certified in the Federal Court of Canada plus interest which had accrued on the said amounts payable pursuant to section 223(3) of the Income Tax Act calculated in accordance with the rate prescribed pursuant to section 161 of the Income Tax Act. ...
FCTD

Maplesden v. Minister of National Revenue, [1998] 2 C.T.C. 162, (sub nom. Maplesden v. R.) 98 D.T.C. 6039

On February 26, 1993, Mrs. Maplesden recovered damages in negligence from that law firm, in the amount of $356,156.20. ...
FCTD

Banff Caribou Properties Ltd. v. Canada (Attorney General), 2023 FC 312

For the same rationale as the CRA’s, courts have found that late-filed elections cannot be accepted for provisions not expressly listed in the ITA and the Regulations as allowing late-filed elections (see Miller v Minister of National Revenue (1992), [1993] 1 CTC 269 (FCA); Hundal v Canada, (2000) 54 DTC 6520 (FC); Terminal Norco; Advanced Agricultural Testing Inc v R, 2009 TCC 190). [29] The CRA also considered the Applicant’s argument that this was an innocent mistake and that it did not engage in retroactive tax planning. ...
FCTD

Sran v. Canada (Citizenship and Immigration), 2024 FC 936

The standard of review [16] The jurisprudence has clearly determined that the standard of reasonableness applies to assessments of credibility made by the RPD and the RAD (Aguebor v Canada (Minister of Employment and Immigration),   (1993) 160 NR 315 (FCA) at para 4; Lawani v Canada (Citizenship and Immigration), 2018 FC 924 at para 13 [Lawani]; Gomez Florez v Canada (Citizenship and Immigration), 2016 FC 659 at para 20; Soorasingam v Canada (Citizenship and Immigration), 2016 FC 691). ...
FCTD

McMillan v. Canada (Attoreny General), 2025 FC 408

The CRA also noted that it had been issuing warnings to taxpayers about the risks of participating in donation tax shelter schemes since 1993. ...
FCTD

Soper v. R., 97 DTC 5407, [1997] 3 C.T.C. 242 (FCA)

(Toronto: Butterworths, 1993) at chapter 5, section B, beginning at 117. ... Campbell, “Directors' Liability for Unremitted Employee Deductions” (1993) 14 Advocates' Q. 453. 32 For example, in some instances the relevant issue will be whether an individual was in fact or in law a director at the relevant time for purposes of imposing personal liability or whether that individual ceased to hold office by operation of a valid resignation. ...
FCTD

The Queen v. Lehmann Bookbinding Ltd., 95 DTC 5063, [1995] 2 CTC 129 (FCTD)

., [1993] A.J. No. 25; The Queen v. Duncan, [1991] 2 C.T.C. 360, 91 D.T.C. 5615. ... See The Queen v. 311326 Alberta Ltd., [1993] A.J. No. 25 (C.A.). Further I think the fact that the Minister may obtain a court authorization ex parte places an obligation on the Minister to act in the utmost good faith and ensure full and frank disclosure of information. ...
FCTD

Angell v. Canada (Minister of National Revenue), 2006 FC 1097

  [8]                Since the deductions and tax credits were denied due to the unscientific nature of ALH’s research and development, on June 7, 1993, the Revenue Canada appeals officer sought the opinion of a second scientific advisor. ... Aqua-Gem Investments Ltd., [1993] 2 FC 425 and Merck & Co. v. Apotex Inc., [2003] F.C.J No. 1925 (CA) (QL), 2003 FCA 291 at paras 19, 25).   ...
FCTD

Double N Earth Movers Ltd. v. Canada, docket T-698-97

However, in response to a Notice of Objection to this decision, on September 10, 1993, the Minister of National Revenue allowed the objection in part on the basis that a small portion of Double N"s activities qualify for the rebate. ... That was replaced in 1993 with the legal legislation.                           ...
FCTD

Canada (Minister of National Revenue) v. Cast Terminals Inc., 2003 FCT 535

Canada, [1993] F.C.J. No. 258 (T.D.) (QL), Justice Denault said this about the appeals under the Act to this Court: These appeals were heard together and deal with identical issues. ... Genest concluded that fifty-eight (58%) percent of the work performed by the Le Tro-porters is the hoisting of the containers. [100]        Counsel for Cast and Racine urged upon me the Tribunal's decision of September 28, 1993, in appeal number AP80-91-190 to AP-91-200 in the matter of Via Rail Canada Inc. and the Minister of National Revenue, which was adopted by Justice Blais in Seaspan International Ltd. v. ...

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