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TCC
Plus Que Noel Inc. v. M.N.R., 2007 TCC 602
Signed at Ottawa, Canada, this 26th day of November 2007. "Paul Bédard" Bédard J. ... (no knowledge) (f) On October 24, 2005, the Worker signed a contract drawn up by the Appellant. ... "Paul Bédard" Bédard J. Translation certified true on this 9th day of January 2008. ...
TCC
CBS Canada Holdings Co. v. The Queen, 2016 TCC 85
Shafer Counsel for the Respondent: Naomi Goldstein and Samantha Hurst ORDER WHEREAS the respondent brought a motion for an Order to strike out the affidavit of Deborah Toaze sworn June 22, 2015; UPON reading the materials filed and hearing from the appellant counsel and respondent counsel; THIS COURT ORDERS THAT: 1. ... [Emphasis Added] [20] In Mayne Pharma (Canada) Inc. v Aventis Pharma Inc., 2005 FCA 50, [2005] FCJ No. 215 (QL), the Federal Court of Appeal notes that motions to strike affidavits should be exceptional, especially where the question is one of relevancy, and prejudice must be demonstrated. ... The motion is about whether or not a settlement agreement is – … i) [sic] Line 11: Ms. ...
FCTD
Leblanc v. Canada (Attorney General), 2010 FC 688
Canada (CRA), 2005 FCA 153, held that the applicable standard of review of a fairness decision of the Minister, under section 152(4.2) of the Act, was reasonableness simpliciter. ... “ Edmond P. Blanchard” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-840-08 STYLE OF CAUSE: CARLYLE LEBLANC v. ... DATED: June 23, 2010 APPEARANCES: Carlyle LeBlanc Surrey, B.C. ...
TCC
McKay v. The Queen, 2016 TCC 233
Wetelainen that, as a result of an audit in 2005 by the Federal Government and a subsequent investigation by the RCMP, the Association had to close its offices across Ontario. ... This contradicts her testimony that she was a “ team leader ”. [14] Mr. ... This paragraph reads as follows: For the purposes of this Act, ... ...
TCC
Millard v. M.N.R., 2008 TCC 353
[3] The Appellant first began delivering papers on May 23, 1999 and he was a carrier continuously from then until December 3, 2005, when he stopped being a carrier. ... Signed at Ottawa, Canada, this 27th day of June, 2008. “M.A. Mogan” Mogan D.J. ... Mogan DATE OF JUDGMENT: May 7, 2008 APPEARANCES: For the Appellant: The Appellant himself Counsel for the Respondent: Melissa Danish Counsel for the Intervenor Fred Bickford COUNSEL OF RECORD: For the Appellant: Name: N/A Firm: N/a For the Respondent: John H. ...
TCC
MacKenzie v. The Queen, 2008 TCC 70 (Informal Procedure)
Signed at Ottawa, Canada, this 30th day of January 2008. “B.Paris” Paris J. ... R., 2005 TCC 263 are applicable to the case at bar: Here, the appellant is not arguing that the legislation itself offends section 15 of the Charter, but maintains rather that the Minister's actions violate section 15. ... Paris DATE OF JUDGMENT: January 30, 2008 APPEARANCES: Agent for the Appellant: Kim Steven Mackenzie Counsel for the Respondent: Julian Malone and Julia Parker COUNSEL OF RECORD: For the Appellants: For the Respondent: John H. ...
TCC
Grenier c. La Reine, 2007 TCC 93
La Reine, 2007 TCC 93 Citation: 2007TCC93 Date: 20070627 Docket: 2000-761 (IT)G BETWEEN: RAYNALD GRENIER, Applicant, and HER MAJESTY THE QUEEN, Respon dent. ... Moreover, in support of his claims at the hearing for his motion, he adduced as Exhibit R-1 some tables that showed income declared for 1967, 1972, 1974 to 1976 and 1978 to 2005. ... • New facts [14] Regarding the argument about new facts, Mr. ...
TCC
Wise v. The Queen, 2019 TCC 196
The Queen, (2005) FCA 329 (“Colubriale”). [47] In Angle, a company controlled by the appellant shareholder, paid for and installed a swimming pool at her residence. ... (My emphasis) V – Analysis [53] As noted by the Respondent, in matters of taxation, form matters (Canada v. ... Annex A CITATION: 2019 TCC 196 COURT FILE NO.: 2016-3191(IT)G STYLE OF CAUSE: VALERIE WISE AND THE QUEEN PLACE OF HEARING: Victoria, British Columbia DATE OF HEARING: September 3, 2019 REASONS FOR JUDGMENT BY: The Honourable Guy R. ...
TCC
Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 263
., Appellant, and HER MAJESTY THE QUEEN, Respondent. By: The Honourable Justice Campbell J. ... So, let me look at what transpired with respect to settlement offers, as this remains the sole determinative factor for an award of costs. [17] The Appellant made an offer to the Respondent on March 15, 2018, “predicated on the basis that the taxpayer complied with the technical requirements of the Act, the waivers preclude the Minister from reassessing the 2001 to 2005 taxation years on the basis of the GAAR, and the GAAR applied to Glenhuron Bank’s years 2006 to 2013.” [18] The Respondent rejected that offer on March 20, 2018 and countered as follows: We are in receipt of the appellant’s settlement offer dated March 15, 2018. ... AND HER MAJESTY THE QUEEN REASONS RESPECTING SUBMISSIONS ON COSTS BY: The Honourable Justice Campbell J. ...
TCC
Wilford v. M.N.R., 2011 TCC 6
Weisman" Weisman D.J. Citation: 2011 TCC 6 Date: January 7, 2011 Dockets: 2009-3411(EI) 2009-3637(CPP) BETWEEN: ALLEN WILFORD, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and SUSAN BONNAR (GIORDANO), Intervener. ... M.N.R. (“ Wiebe Door ”) [3]; and 671122 Ontario Limited v. Sagaz Industries Canada Inc. (“ Sagaz ”) [4]. ... No. 375 (F.C.A.) [10] Above, footnote 4, at paragraph 47 [11] Above, footnote 7 [12] Above, footnote 2, at paragraph 17 [13] Woodland Insurance Ltd. v.M.N.R., [2005] T.C.J. ...