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FCA
Lanno v. Canada (Customes & Revenue Agency), 2005 FCA 153
Canada (Customes & Revenue Agency), 2005 FCA 153 Date: 20050502 Docket: A-478-04 Citation: 2005 FCA 153 CORAM: ROTHSTEIN J.A. ... "I agree. Marshall Rothstein J.A." "I agree. ... " FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-478-04 APPEAL FROM THE ORDER OF MADAM JUSTICE SNIDER DATED JUNE 28, 2004 IN DOCHET T-2282-03 STYLE OF CAUSE: DENIS LANNO and CANADA CUSTOMS AND REVENUE AGENCY PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: April 27, 2005 REASONS FOR JUDGMENT BY: SHARLOW J.A. ...
FCA
Dow & Duggan Log Homes International (1993) Limited v. Canada, 2021 FCA 66
HER MAJESTY THE QUEEN PLACE OF HEARING: Heard by online video conference hosted by the Registry DATE OF HEARING: March 24, 2021 REASONS FOR JUDGMENT BY: STRATAS J.A. ... RIVOALEN J.A. DATED: March 31, 2021 APPEARANCES: Melanie Petrunia For The Appellant Stan McDonald For The Respondent SOLICITORS OF RECORD: Nijhawan McMillan Petrunia Halifax, Nova Scotia For The Appellant Nathalie G. Drouin Deputy Attorney General of Canada For The Respondent ...
FCA
Addison & Leyen Ltd. v. Canada, 2006 DTC 6248, 2006 FCA 107
Facts 6 (1) The state of affairs in October of 1988 7- 10 (2) Payments made by York between October of 1988 and October of 1989 11- 13 (3) The sale of York to Senergy 14- 19 (4) Payments made by Addison in 1989 20- 21 (5) Communications with tax officials in 1990, 1991 and 1992 22 (6) The reassessment of York in 1992 23- 24 (7) Events in 1989 and 1999 25- 28 (8) The section 160 assessments 29- 35 C. ... 49- 51 (i) The elements of section 160 52- 54 (ii) The history of section 160 55- 56 (iii) Section 160 and dividends 57- 60 (iv) The application of section 160 to other corporate payments 61- 62 (v) Section 160 as a collection tool 63- 64 D. ... Sharlow" J.A. "I agree. ...
FCA
Canada (National Revenue) v. Al Saunders Contracting & Consulting Inc., 2020 FCA 89
AL SAUNDERS CONTRACTING & CONSULTING INC. APPEAL DEALT WITH IN WRITING WITHOUT appearance of the parties REASONS FOR JUDGMENT BY: DAWSON J.A. ... LOCKE J.A. DATED: MAY 15, 2020 WRITTEN REPRESENTATIONS BY: Valerie Meier Allan Mason For The Appellant SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada For The Appellant Felesky Flynn LLP Calgary, Alberta For The Respondent ...
FCA
D & J Driveway Inc. v. Canada (Minister of National Revenue), 2003 FCA 453
D & J Driveway Inc. v. Canada (Minister of National Revenue), 2003 FCA 453 Date: 20031127 Docket: A-512-02 Citation: 2003 FCA 453 CORAM: DÉCARY J.A. ... Tr., LL.L. FEDERAL COURT OF APPEAL SOLICITORS OF RECORD FILE: A-512-02 STYLE OF CAUSE: D & J DRIVEWAY v. ... REASONS FOR JUDGMENT OF THE COURT: LÉTOURNEAU J.A. DATE OF REASONS: NOVEMBER 27, 2003 APPEARANCES: Lyne Thériault and Marie-Hélène Montminy FOR THE APPLICANT Martin Gentile and Alain Gareau FOR THE RESPONDENT SOLICITORS OF RECORD: Pouliot, L'Écuyer FOR THE APPLICANT Sainte-Foy, Quebec Department of Justice- Canada FOR THE RESPONDENT Montréal, Quebec ...
FCA
James Richardson & Sons Limited v. Minister of National Revenue, [1982] CTC 248, 82 DTC 6211
James Richardson & Sons Limited v. Minister of National Revenue, [1982] CTC 248, 82 DTC 6211 Le Dain, J:—The section 28 application must be dismissed for lack of jurisdiction on the ground that a requirement for information or documents issued under subsection 231(3) of the Income Tax Act, SC 1970-71-72, c 63. is not a decision required by law to be made on a judicial or quasi-judicial basis within the meaning of section 28 of the Federal Court Act, RSC 1970, c 10 (2nd Supp). Cf MNR v Coopers & Lybrand, [1979] 1 SCR; [1978] CTC 829; 78 DTC 6528. ...
FCA
Trans World Oil & Gas Ltd. v. R., [1998] 3 CTC 37
Trans World Oil & Gas Ltd. v. R., [1998] 3 CTC 37 Pratte J.A.: We do not need to hear you, Mr. ...
FCA
I.D. Foods Superior Corp. v. Deputy Minister of National Revenue (Customs & Excise), [1998] 3 CTC 227
Deputy Minister of National Revenue (Customs & Excise), [1998] 3 CTC 227 Décary J.A.: Subsection 68(1) of the Customs Act as it read prior to December 1995, required that an appeal of a decision of the Canadian International Trade Tribunal be made with leave of a judge of the Trial Division of the Federal Court within ninety days after the date the decision was made. ... C.A.); Deputy Minister of National Revenue (Customs & Excise) v. Philips Electronics Ltd. (1993), 151 N.R. 178 (Fed. C.A.); Deputy Minister of National Revenue (Customs & Excise) v. Wilbur- Ellis Co. of Canada (1995), 129 D.L.R. (4th) 579 (Fed. ...
FCA
Hudson Bay Mining & Smelting Co. v. R., 99 DTC 5269, [1999] 3 CTC 76 (FCA)
Hudson Bay Mining & Smelting Co. v. R., 99 DTC 5269, [1999] 3 CTC 76 (FCA) Strayer J.A.: This is an appeal from a judgment of the Tax Court of Canada. ... Thomas Summerson & Sons Ltd. [1] and R. v. Immobilière Canada Ltd. [2] are distinguishable in that they each involved the purchase of a debt instrument by someone other than the debtor under that instrument. ...
FCA
Her Majesty the Queen v. Coopers & Lybrand Limited, Agent for Mercantile Bank of Canada and Receiver and Manager of Venus Electric Limited, [1980] CTC 406, 80 DTC 6323
Coopers & Lybrand Limited, Agent for Mercantile Bank of Canada and Receiver and Manager of Venus Electric Limited, [1980] CTC 406, 80 DTC 6323 Urie, J:—The respondent seeks to have this Court reconsider its judgment herein on two grounds: (a) that the sum referred to on pages 15 and 16 of the reasons for judgment in respect of the amount which the respondent had available to it to pay on account of wages was $190,270 rather than $196,207.01 as shown therein; (it has been conceded by the appellant that the latter figure is incorrect and the proper figure for inclusion in the reasons is $190,270 and the reasons for judgment will be so amended), and (b) that the pronouncement as it relates to costs does not agree with the reasons. ... While the applicant, Coopers & Lybrand Limited, quite properly brought to the Court’s attention the error in the figures shown on pages 15 and 16 of the reasons, correction of such error could have been accomplished quite simply by applying to the Court to effect the necessary correction without combining that application with the application for reconsideration of the Court’s disposition of costs. ...