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Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 at para. 8). [13] There have been relatively few cases where the interplay of subsections 115(4) and 119(2) of the OBCA has been examined and none of them are from this Court or the Ontario Court of Appeal. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: April 26, 2022   REASONS FOR JUDGMENT BY: GLEASON J.A.   ... MONAGHAN J.A.   DATED: july 7, 2022   APPEARANCES: Craig J. Allen   For The Appellant   Meaghan Mahadeo Jason Stober   For The Respondent   SOLICITORS OF RECORD: Craig Allen Law Windsor, Ontario   For The Appellant   A. ...

LEBLANC J.A.   BETWEEN: SHENGDI CHEN Appellant and HIS MAJESTY THE KING Respondent Heard at Toronto, Ontario, on June 22, 2023. ... Canada (Attorney General), 2002 FCA 370 at para. 9 (Miller); Feeney v. ... "René LeBlanc" J.A.   FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-127-22   STYLE OF CAUSE: SHENGDI CHEN v. ...

Standard of review [22]            Housen v. Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235, sets out the appropriate standard of review for appeals of Tax Court of Canada judgments. ... Mainville” J.A.       “I agree.             J.D. Denis Pelletier J.A.”   ... TRUDEL J.A.   REASONS DATED:                                                              November 28, 2011     APPEARANCES:   Dominic Belley For the appellant   Christian Boutin For the Respondent     SOLICITORS OF RECORD:   Ogilvy Renault Montréal, Quebec For the appellant     Larivière Meunier Québec, Quebec   For the Respondent       ...

MacDonald would be required to make payments to TDSI. [10]   The Forward Contract was to terminate on its Forward Date, initially June 26, 2002 and later extended to March 26, 2006. ... Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235, at para. 8). The application of this definition to the facts at hand gives rise to a question of mixed fact and law which, in the absence of an extricable legal error, cannot be interfered with unless an overriding and palpable error can be demonstrated (Ibidem at paras. 36 and 37).-   The analytical approach [48]   This appeal does not turn on whether the Tax Court judge chose the proper analytical approach in addressing the issue before her because regardless of the approach taken, the matter must ultimately be resolved by ascertaining whether the Forward Contract is a hedging instrument. ... Roth   For The Respondent SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada   For The APPELLANT   Davies Ward Phillips & Vineberg LLP Toronto, Ontario   For The Respondent     ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235: correctness for questions of law and palpable and overriding error for questions of fact and questions of mixed fact and law, except where an extricable question of law arises. [22] In his oral submissions, Mr. ... DEPARTMENT OF FINANCE CANADA     PLACE OF HEARING: Winnipeg, Manitoba   DATE OF HEARING: November 3, 2022   REASONS FOR JUDGMENT BY: PELLETIER J.A.   ... RIVOALEN J.A.   DATED: NOVEMBER 21, 2022   APPEARANCES: Crispin Kemp   For The Appellant (on their own behalf)   Soniya Bhasin   For The Respondent   SOLICITORS OF RECORD: A. ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235. Consequently, the Judge’s rulings on questions of fact are reviewable on a correctness standard. ... Fitzwilliam, 2002 FCT 598 (CanLII), he stated the following: [51]      Rule 147 allows the Court to consider the documents to be validly served if it is satisfied that the document came to the notice of the person to be served. ... HER MAJESTY THE QUEEN AND 9011‑1345 QUÉBEC INC.   PLACE OF HEARING: Québec, Quebec     DATE OF HEARING: December 17, 2015     REASONS FOR JUDGMENT: NADON J.A.     ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235, at paragraph 37). However, the abuse analysis proceeds in two stages. ... Canada, 2001 FCA 260, [2002] 2 F.C. 288. [34]   There, the liquidator of Standard Trust Company sought to maximize the recovery from the disposition of Standard’s assets. ... ATTORNEY GENERAL OF CANADA     AND DOCKET: A-141-17     STYLE OF CAUSE: PERRY WILD v. ...

Nikolaisen, 2002 SCC 33 at para. 10, [2002] 2 S.C.R. 235. [30]   Mr. Smith concedes that the Tax Court judge correctly cited the governing legal principles. ... R., [2002] 4 F.C. 443,  2002 FCA 177, affirming [2001] 1 C.T.C. 2356;  O’Neil v. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Calgary, Alberta   DATE OF HEARING: June 11, 2018   REASONS FOR JUDGMENT BY: LASKIN J.A.   ...

In 2000, Alcan successfully merged with Algroup but its plans with respect to Pechiney did not materialize. [8]   In 2002, Alcan again considered the possibility of a transaction with Pechiney. ... Morgan Stanley, as the lead investment firm, made a number of presentations to the Alcan board of directors from December 2002 through July 2003. ... Nikolaisen, 2002 SCC 31, [2002] 2 S.C.R. 235 (Housen), namely, correctness for questions of law and palpable and overriding error for questions of fact and questions of mixed fact and law, except where it is possible to identify an extricable error of law in which case the standard of review for that question is correctness. ...

NADON J.A.                         PELLETIER J.A.   BETWEEN: HER MAJESTY THE QUEEN Appellant and MARTINE LANDRY Respondent             Heard at Montréal, Quebec, on May 18, 2010. ... She therefore underwent a net worth audit for the 1998 to 2002 taxation years. The audit led to approximately $602,627 being added to the respondent’s income, broken down as follows: $91,388 for 1998; $89,146 for 1999; $68,068 for 2000; $181,849 for 2001 and $172,176 for 2002. ...