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Justice Boswell BETWEEN: MARCO VALLELUNGA Applicant and HER MAJESTY THE QUEEN IN RIGHT OF CANADA AS REPRESENTED BY THE MINISTER OF REVENUE Respondent JUDGMENT AND REASONS [1]                In December 2002, the Applicant’s father, Giuseppe Vallelunga, transferred real property known as 259 Regina Avenue in Thunder Bay, Ontario, to the Applicant for less than fair market value. ... I.                    Background [2]                In a letter dated February 16, 2006, the Canada Revenue Agency notified the Applicant of the CRA’s intention to assess the Applicant under subsection 160(2) of the Act for the amount which was the lesser of, the benefit he received from the non-arm’s length transfer of the Regina Avenue property in 2002, and the amount of his father’s outstanding tax debt which, at the time of the transfer, totalled $110,325.85. ... Pentney Deputy Attorney General of Canada Toronto, Ontario   For The Respondent     ...

ITO – Int’l Terminal Operators v Miida Electronics, [1986] 1 S.C.R. 752. ... Analysis [13] I begin my analysis by noting there is no dispute between the parties that the DPP has the discretion to stay private prosecutions: Krieger v Law Society of Alberta, 2002 SCC 65, [2002] 3 S.C.R. 372 at para 46. ... DATED: February 17, 2023   WRITTEN REPRESENTATIONS BY: Juanita Wood   For The Applicant (ON HER OWN BEHALF) William Lu For The Respondent   SOLICITORS OF RECORD: Attorney General of Canada Whitehorse, Yukon Territory For The Respondent     ...

Rex, 2002 SCC 42, [2002] 2 S.C.R. 559 (S.C.C.) and Canada Trustco Mortgage Co. v. ... Brown” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-413-19   STYLE OF CAUSE: LEE PASSEY v CANADA (ATTORNEY GENERAL)   PLACE OF HEARING: OTTAWA, Ontario   DATE OF HEARING: OCTOBER 8, 2019   JUDGMENT AND REASONS: BROWN J.   DATED: OCTOBER 25, 2019   APPEARANCES: Joshua M. Juneau For The applicant   Taylor Andreas For The respondent   SOLICITORS OF RECORD: Michel Drapeau Law Office Ottawa, Ontario   For The applicant   Attorney General of Canada Ottawa, Ontario   For The respondent     ...

Cordeau Inc., 2002 FCA 228 (“ Gadbois”) to note the ‘broad jurisdiction’ of the Court to permit the enforcement of judgments against non-parties in certain circumstances: [25] More recently, the Federal Court of Appeal confirmed that this Court has broad jurisdiction to decide issues which arise in the enforcement of its judgments, including whether the corporate veil should be lifted: Canada (Minister of National Revenue) v Gadbois, 2002 FCA 228 (CanLII), [2003] 1 C.T.C. 353 (F.C.A.) ... He is seeking a second financier for 20 % (US $ 2 million) to complete the Pilot. ... DATED: july 27, 2022   APPEARANCES: Scott R. Campbell   For The Plaintiff   SOLICITORS OF RECORD: Stewart McKelvey Barristers and Solicitors Halifax, Nova Scotia   For The Plaintiff     ...

Jarvis, 2002 SCC 73 at paras. 57 and 62, [2002] 3 S.C.R. 757 (Jarvis #2). [270]   In light of the self-assessing and self-reporting nature of the income tax scheme, the Supreme Court further held in McKinlay Transport that the Minister must be given broad powers in supervising the regulatory scheme: at 648. [271]   Given the regulatory nature of income tax legislation and the scheme that it enacted, the Supreme Court found in McKinlay Transport that the Hunter v. ... Canada, 2002 SCC 23, [2002] 1 S.C.R. 769, “once a ground is found to be analogous, it is permanently enrolled as analogous for other cases”: at para. 41, citing Corbiere, above at para. 8. ... Québec (Attorney General), 2002 SCC 84, [2002] 4 S.C.R. 429, the central lesson of Law was the need for a contextual inquiry in order to establish whether a statutory distinction conflicts with the purpose of subsection 15(1) of the Charter, such that “a reasonable person in circumstances similar to those of the claimant would find that the legislation which imposes differential treatment has the effect of demeaning his or her dignity”: at para. 25. [404]   In R. v. ...

Legal (the applicant) of a decision by the Minister of National Revenue (the Minister) dated August 5, 2009, denying the applicant a renewal for a licence to manufacture tobacco products or to dispose of, sell, offer for sale, purchase or possess unpackaged and unstamped raw leaf tobacco or tobacco products, including partially manufactured tobacco under the Excise Act, 2001, S.C. 2002 c. 22 (the Excise Act).     ...   [34]            I will exercise my discretion in this matter and not award any costs.                       ... Legal   ON HER OWN BEHALF Tim Doyle   FOR THE RESPONDENT     SOLICITORS OF RECORD:   None     Myles J. ...

Canada (Attorney General), 2003 DTC 5712, 2003 FC 1346 (FCTD) Date: 20031114 Docket: T-1385-02 Citation: 2003 FC 1346 BETWEEN:                                                             JOAN BARBARA HEELS                                                                                                                                                        Applicant                                                                              - and-                                                 ATTORNEY GENERAL OF CANADA                                                        and CANADA CUSTOMS AND                                                                 REVENUE AGENCY                                                                                                                                                Respondents                                                             REASONS FOR ORDER SIMPSON J. [1]                 The Applicant has applied for judicial review of a decision of the Canada Customs and Revenue Agency (the "CCRA") dated May 1, 2002, denying her request for a review of an earlier decision refusing her relief from interest and late filing penalties imposed due to the late filing of her income tax returns for the 1995, 1998 and 1999 taxation years. [2]                 In spite of repeated demands and reminders, the Applicant's 1995 return was filed on April 11, 2000, her 1998 return was filed on April 3, 2001, and her 1999 return was filed on June 13, 2001. [3]                 The amounts at issue are approximately $12,900 in penalties and interest charges of $8,200. ... Thereafter, the Applicant requested a review and the second negative decision is found in a letter dated May 1, 2002. ... Tamara Sugunasiri                                                             For RESPONDENT SOLICITORS OF RECORD:                                                                                                        Mr. ...

Canada (Minister of Citizenship and Immigration), 2002 FCA 125 (CanLII), [2002] 4 F.C. 358 (C.A.), at paras. 12 and 31; Kolosovs v. ... Canada (Minister of Citizenship and Immigration), [2003] 2 FCR 555, 2002 FCA 475 [Hawthorne]; Legault v. Canada (Minister of Citizenship and Immigration), [2002] 4 FCR 358, 2002 FCA 125). [30]            As the officer noted, in the vast majority of cases, the best interests of the child argue in favour of keeping the child in Canada. ...

II.   Background [4]   This matter follows from the 2007 conviction of Mr. ... In Hospira Healthcare, a unanimous five-judge panel adopted the standard enunciated by the Supreme Court of Canada in Housen v Nikolaisen, 2002 SCC 33 [Housen]. [23]   In Housen, the Supreme Court held that the applicable standard of review is that of palpable and overriding error for questions of fact and questions of mixed fact and law. ... VI.   Conclusion [63]   The motion is dismissed. [64]   The Respondents seek and shall have their costs on this motion to appeal. ...

On May 9, 2002, Canada Customs and Revenue Agency (CCRA) assessed the respondent for income taxes owing for the taxation years 1997, 1998, 1999 and 2000. ... Instead, on November 5, 2002, an "independent accountant" forwarded correspondence to CCRA, on behalf of the respondent, demanding that CCRA respond to 7 questions and warning that failure to respond would be taken, by the respondent, as an admission that the assessments were "without legal foundation". [6]                 By January 14, 2003, the respondent's liability with respect to the 1997-2000 taxation years stood at $39,135.07. ... CCRA has not taken any other collection steps against the respondent. [7]                 On March 8, 2003, the "independent public accountant" forwarded further correspondence to CCRA advising that the respondent's tax returns for 1997-2000 were filed and received by the Southern Interior Tax Services Office on August 8, 2002. ...