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FCA

Cridge v. Canada, 2016 FCA 87

BOIVIN J.A.   BETWEEN: LOVEY CRIDGE Appellant and HER MAJESTY THE QUEEN Respondent Heard at Vancouver, British Columbia, on March 15, 2016. ... REASONS FOR JUDGMENT OF THE COURT BY: RYER J.A.   Date: 20160315 Docket: A-189-15 Citation: 2016 FCA 87 CORAM: RYER J.A. ... 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

Canada (Attorney General) v. Fink, 2017 FCA 87

DE MONTIGNY J.A.   BETWEEN: ATTORNEY GENERAL OF CANADA Appellant and RON FINK Respondent Heard at Edmonton, Alberta, on April 25, 2017. ... NEAR J.A.   Date: 20170427 Docket: A-276-16 Citation: 2017 FCA 87 CORAM: STRATAS J.A. ... RON FINK   PLACE OF HEARING: Edmonton, Alberta DATE OF HEARING: April 25, 2017 REASONS FOR JUDGMENT BY: DE MONTIGNY J.A. ...
FCA

Horseman v. Canada, 2016 FCA 252

GLEASON J.A.   BETWEEN: RICK HORSEMAN Appellant and HER MAJESTY THE QUEEN IN RIGHT OF CANADA AND HER MAJESTY THE QUEEN IN RIGHT OF CANADA AS REPRESENTED BY CANADA REVENUE AGENCY Respondents Heard at Edmonton, Alberta, on October 17, 2016. ... REASONS FOR JUDGMENT OF THE COURT BY: DE MONTIGNY J.A.   Date: 20161017 Docket: A-82-16 Citation: 2016 FCA 252 CORAM: GAUTHIER J.A. ... Pentney Deputy Attorney General of Canada Edmonton, Alberta FOR THE RESPONDENTS   ...
FCA

Canada v. Pomeroy Acquireco Ltd., 2021 FCA 187

LEBLANC J.A.   BETWEEN: HER MAJESTY THE QUEEN Appellant and POMEROY ACQUIRECO LTD. ... Canada, [1994] 1 F.C. 3, [1993] 2 C.T.C. 213 at p. 6; Merck & Co., Inc. v. ...
FCA

McNeeley v. Canada, 2021 FCA 218

LEBLANC J.A.   Date: 20211115 Dockets: A-260-20 (Lead) A-261-20 A-262-20 Citation: 2021 FCA 218 CORAM: WEBB J.A. ... & W. Paul, Ltd. v. Wheat Commission, [1937] A.C. 139 (H.L.)), unless a statute so authorizes (Re Gray (1918), 57 S.C.R. 150). ... François Daigle Deputy Attorney General of Canada For The Respondent   ...
FCA

Canada v. Thompson, 2022 FCA 119

RIVOALEN J.A.   BETWEEN: HER MAJESTY THE QUEEN Appellant and LARRY THOMPSON and THOMPSON BROS. ... RIVOALEN J.A.   DATED: jUNE 20, 2022   APPEARANCES: Ron D.F. Wilhelm Eric Brown For The Appellant Robert A. ...
FCA

Brightline Foundation v. Canada (National Revenue), 2023 FCA 23

REASONS FOR ORDER BY: WEBB J.A.   Date: 20230202 Docket: A-212-22 Citation: 2023 FCA 23 Present: WEBB J.A. ... However, this argument is not supported by the wording of paragraph 168(2)(b) of the Act: the Minister may, after the expiration of 30 days from the day of mailing of the notice, or after the expiration of such extended period from the day of mailing of the notice as the Federal Court of Appeal or a judge of that Court, on application made at any time before the determination of any appeal pursuant to subsection 172(3) from the giving of the notice, may fix or allow, publish a copy of the notice in the Canada Gazette, [10] Paragraph 168(2)(b) of the Act merely allows this Court (as a result of an application brought by a registered charity under this paragraph) to fix or allow a longer period of time before a copy of the notice sent to the registered charity under subsection 168(1) of the Act could be published in the Canada Gazette. ... François Daigle Deputy Attorney General of Canada For The Respondent   ...
FCA

Minister of National Revenue v. Cassidy Limitée, Faema Distributeur Inc. And Russell Food Equipment Limited, [1994] 2 CTC 108

(Customs & Excise), [1984] C.T.C. 75, 84 D.T.C. 6081 (F.C.A.) is authoritative on this point at pages 79-80 (D.T.C. 6084-85): It appears to me that the expressions "manufacturer or producer”, “manufactured or produced” and “manufacture or production”, which are found in various places and contexts in the Act, are used for differing purposes and that it is wrong to try to interpret one by reference to what another means or has been held to include either in a particular context or in general. ... (Customs & Excise) (1983), 18 Ex. C.R. 31, [1983] C.T.C. 416, at page 33 (C.T.C. 418), stated: The ordinary and accepted meaning of the word "marchandises" (goods) is that of items circulated on the commercial market, items intended for sale. ...
FCA

Jewish National Fund of Canada Inc. v. Canada (National Revenue), 2025 FCA 114

REASONS FOR ORDER BY: WALKER J.A.   Date: 20250610 Docket: A-245-24 Citation: 2025 FCA 114 Present: WALKER J.A. ... DATED: juNE 10, 2025 WRITTEN REPRESENTATIONS BY: Andrew Brodkin Nando De Luca For The Appellant Adam Aptowitzer Lisa Watzinger For The Appellant Linsey Rains Alex Nguyen Mengjiao Liu For The Respondent SOLICITORS OF RECORD: GOODMANS LLP Toronto, Ontario For The Appellant KPMG Law LLP Toronto, Ontario For The Appellant Shalene Curtis-Micallef Deputy Attorney General of Canada For The Respondent   ...

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