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FCA

Hutton v. Sayat, 2022 FCA 30

Sayat, 2022 FCA 30 Date: 20220216 Docket: A-18-21 Citation: 2022 FCA 30 Present: GARNET MORGAN, Assessment Officer   BETWEEN:     KRISTEN ERNEST HUTTON     Appellant     and     RIA SAYAT, LYNN DUHAMIE also known as STEPHANIE DUHAIME the former Canadian Charge d'affaires for the Republic of Iraq, THE ATTORNEY GENERAL OF CANADA (on behalf of THE DEPARTMENT OF NATIONAL DEFENCE, CANADIAN SECURITY INTELLIGENCE SERVICE and CANADIAN SECURITY ESTABLISHMENT), HER MAJESTY THE QUEEN     Respondents   Assessment of costs without appearance of the parties. ... REASONS FOR ASSESSMENT BY: GARNET MORGAN, Assessment Officer   Date: 20220216 Docket: A-18-21 Citation: 2022 FCA 30 Present: GARNET MORGAN, Assessment Officer   BETWEEN:     KRISTEN ERNEST HUTTON     Appellant     and     RIA SAYAT, LYNN DUHAMIE also known as STEPHANIE DUHAIME the former Canadian Charge d'affaires for the Republic of Iraq, THE ATTORNEY GENERAL OF CANADA (on behalf of THE DEPARTMENT OF NATIONAL DEFENCE, CANADIAN SECURITY INTELLIGENCE SERVICE and CANADIAN SECURITY ESTABLISHMENT), HER MAJESTY THE QUEEN     Respondents   REASONS FOR ASSESSMENT GARNET MORGAN, Assessment Officer I. ... Canada, 2002 FCA 397, at paragraph 4, the Assessment Officer stated the following regarding the issue of an affiant’s knowledge and the filing of affidavits for an assessment of costs: 4. ...
FCA

Canada v. Dow Chemical Canada ULC, 2022 FCA 70, leave granted 23 February 2023

LOCKE J.A.   Date: 20220426 Docket: A-318-20 Citation: 2022 FCA 70 CORAM: WEBB J.A. ... Nikolaisen, 2002 SCC 33). IV. Analysis [23] The transfer pricing rules are set out in section 247 of the ITA. ... François Daigle Deputy Attorney General of Canada FOR THE APPELLANT EY Law LLP Toronto, Ontario FOR THE RESPONDENT   ...
FCA

St. Michael Trust Corp. v. Canada, 2010 DTC 5189 [at at 7361], 2010 FCA 309, aff'd sub nom Fundy Settlement v. Canada, 2012 DTC 5063 [at 6881], 2012 SCC 14

Michael Trust Corp. were sold in 2002 and again in 2008, but those transactions are not relevant to any of the issues raised in this appeal ... I would award the Crown one set of costs.     “K. Sharlow” J.A.     “I agree            M. ... Barbour   FOR THE APPELLANT   Elizabeth Chasson Erin Strashin Margaret Nott FOR THE RESPONDENT               SOLICITORS OF RECORD:   Thorsteinssons LLP, Tax Lawyers Toronto, Ontario   FOR THE APPELLANT   Myles J. ...
FCA

Lister v. The Queen, 94 DTC 6531, [1994] 2 CTC 365 (FCA)

Ct. 1997 (1987) at page 2002: Legislatures have especially broad latitude in creating classifications and distinctions in tax statutes. ... Turpin, [1989] 1 S.C.R. 1296, 48 C.C.C. (3d) 8, 69 C.R. (3d) 97; Rudolf Wolff & Co. v. ... It is, of course, obvious that legislatures may and to govern effectively must treat individuals and groups in different ways. ...

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