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See also at 245 where IOGC supported in its submission to the Minister the Manager's right to make decisions and rules in a retroactive manner. [11] For a definition of the word "retrospectivity", see [1977] 1 S.C.R. 271 "> Gustavson Drilling (1964) Ltd. ... [Je souligne] [14] The Attorney General of Alberta and The Minister of Lands and Mines of Alberta and Huggard Assets Limited and The Attorney General of Canada, [1951] S.C.R. 427 "> [1951] S.C.R. 427 at 437-41: revised on other grounds [1953] A.C. 420 (P.C). [15] A.B. pp. 81 and 120. [16] A.B. at 169. [17] A.B. at 171. ...

.: — This appeal is taken as to two paragraphs relating to costs in an interlocutory order by the Tax Court joining one Helga Georg as a party to an appeal brought by the respondent against the appellant. ... We do not regard the failure of the counsel for the respondent to request solicitor/client costs as alone fatal to the decision to award them, since in our view courts should have discretion to impose them on their own motion where warranted — but only after alerting counsel that such costs are under consideration and allowing the opportunity for presentation of both sides of the argument. ...

doing business, the appellant has had a dispute with the office of Revenue Canada, Customs & Excise, with respect to its liability for the payment of sales taxes on the septic tanks it was manufacturing. ... The “transitional” provision enacted in 1985 will be in force until it has been repealed—which is not the case—or until it has become obsolete (see subsection 2(2) of the Interpretation Act, R.S.C. 1985, c. 1-21) — which will not be the case until all applications filed before the coming into force of the 1985 Act have been dealt with. ...

.: — This is an appeal against a judgment of Addy, J. of the Trial Division of this Court whereby, upon motion made by the defendant, Her Majesty the Queen, pursuant to rule 419(1)(a) [1] of the Federal Court Rules, the action herein was dismissed on the ground that the statement of claim disclosed no reasonable cause of action. ... No addition to the statement of claim could alter the real nature of the action and this is why, be it said incidentally, that I would now deny the application for leave to amend made orally by counsel for the applicant in the course of the hearing — and then taken under advisement. 2. ...

Is it not the most basic rule of construction that the grammatical and ordinary sense of the words be adhered to unless there is specific reason, — such as the context or the absurdity of the result arrived at — not to do so and the Board gives no reason here and indeed I see none (cf. ...

On this interpretation, subsection (7) could have application to taxpayers directly involved in contesting departmental interpretations before the Tariff Board or a Court or to those affected by an authoritative re-interpretation — this third group could include all taxpayers. ... A taxpayer who pays his taxes in good faith and under the general compulsion of the law should not be penalized for not challenging his Government’s right to the tax at every stage — annually, as recommended before us by counsel for the respondent. ... It provides that costs shall not be awarded — “unless the Court, in its discretion, for special reason, so orders” Since no special reasons were advanced, and none appear from the record, I would make no order respecting costs. ...

Each partnership borrowed the following capital amounts from the First National Bank of Chicago (‘FNBC’) to finance their real estate ventures: (a) PA- US $ 48,512,600; (b) JHA- US $2,387,400; and (c) CTA- US $ 3,200,000. ... In reaching this conclusion, the Tax Court Judge made the following findings: … I do not think that the fact that the appellant paid Society Hill’s obligation under the March 1, 983 agreement constituted a fulfilment of the appellant’s obligation under its guarantee to the Bank. ... T.D.), at 6221. 5 > Cadillac Fairview, supra note I at 409. 6 McHale v. ...

He said at page 468 (D.T.C. 5333): In general it may be observed that U.S. federal laws now seem to avoid using the word "import" to describe goods coming from Puerto Rico to the United States, referring to them instead as being “brought into the United States”, "coming to the United States”, or being for “ shipment to the United States”. ... In my judgment, it is impossible to assert that, within the meaning of that clause, the words “ if war breaks out” mean, “if war is recognised to have broken out by His Majesty's government recognizing it, if His Majesty's govern ment" had recognised that war had broken out, it may be — and I say no more — that a statement to that effect by His Majesty's government would be a matter which, even when dealing with a document of this kind, the court would be bound to accept. ...

Finally, the learned judge followed the decision of this Court in Johnson & Johnson Inc. v. ... This Court was faced with a similar issue in Johnson & Johnson Inc. v. ... Sanford & Brooks Co., 282 U.S. 359, 365 (1931). Nevertheless, strict adherence to an annual accounting system would create transactional inequities. ...

(Customs & Excise), [1984] C.T.C. 75, 84 D.T.C. 6081; Entreprises Kato Inc. v. ... (Customs & Excise) (1983), 18 Ex. C.R. 31, [1983] C.T.C. 416. Hugessen J.A. ... (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. ...