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  [6]   For the following reasons, I conclude that Rovi/TiVo’s motion should be dismissed in its entirety. ... The rule contemplates that requests for documents are to be made in relation to specific documents. [48]   The Court also has the discretion to order examinations of non-parties under Rule 238, however, such relief should not be routinely ordered “and should not become common place”: BMG Canada Inc v Doe, 2005 FCA 193 at para 26. ... AND VIDEOTRON LTD.   PLACE OF HEARING: TORONTO, Ontario   DATE OF HEARING: SEPTEMBER 17, 2019   ORDER AND REASONS: LAFRENIÈRE J.   ...

(the “ Act ”). As a result, paragraph 118.1(13)(c) of the Act was triggered. ... (Canada Trustco Mortgage Co. v Canada, [2005] 2 S.C.R. 601, 2005 SCC 54 (SCC) at para 11). ... Rossiter, Chief Justice DATE OF JUDGMENT: September 28, 2021 APPEARANCES: Counsel for the Appellant: Rebecca Potter Counsel for the Respondent: Dominik Longchamps Andrew Miller COUNSEL OF RECORD: For the Appellant: Name: Rebecca Potter   Firm: Thorsteinssons LLP For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada     ...

Justice Scott    BETWEEN:   NICOLE (NORA) HÉROLD       Plaintiff   and       HER MAJESTY IN RIGHT OF CANADA ET AL CANADA REVENUE AGENCY (CRA) AND THE PARTIES TO THE OFFENCES: EMPLOYMENT INSURANCE (EI), HUMAN RESOURCES AND SOCIAL DEVELOPMENT CANADA (HRSDC) SUDBURY TAXATION CENTRE       Defendants                    REASONS FOR JUDGMENT AND JUDGMENT         I.          ... The plaintiff did not appeal that decision and voluntarily repaid the overpayment by cheque payable to the order of the Receiver General for Canada dated July 9, 2004. ·                     Over the course of the years 2004 and 2005, the plaintiff received several letters regarding her debt from the defendants, more specifically, from the Department. ... Three different seizure codes appear on the plaintiff’s pay stubs, although all of these are in fact set-off transactions under subsection 155(1) of the Financial Administration Act. ·                     Between April 6, 2005, and September 30, 2008, the accounting system (DARS) of the Department, one of the defendants, shows that a total amount of $16,343.46 was credited to the plaintiff’s account (type 190 – payments from other sources). ·                     In June 2008, it was discovered that the plaintiff had received an Employment Insurance overpayment of $383.00. ...

arranging for charities; 2.   appraisal; 3.   shipping; 4.   quality inspection; and 5.   ... In Canada (Attorney General) v Nash, 2005 FCA 386, 2005 DTC 5696, the Federal Court of Appeal stated the following in relation to the applicable fair market value test when it quoted the Henderson Estate appeal: 8.   ... That describes precisely the mode of valuation made by Tropper. … [64]   The above-noted definition has been the definition which was applied by the Federal Court of Appeal in the above-noted case, as well in Klotz v The Queen, 2005 FCA 158, 2005 DTC 5279. [65]   The analysis conducted below applies the Henderson test, as it relates to the fair market value of the donated art in question on the date on which the art was donated. ...

III.   Issues [16]   The issues are: Is the Minister’s Decision reasonable? ... It is also consistent with past jurisprudence of this Court which has preferred the strict language of the ETA over its broader purpose, in circumstances where a textual interpretation produces a result that is contrary to the spirit of the ETA: Axa, above at paras 47-51. [52]   However, if I had applied the correctness standard to this issue, I may have come to the opposite conclusion. [53]   It has long been established as a matter of statutory interpretation that “the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”: Canada Trustco Mortgage Co v Canada, 2005 SCC 54 at para 11. ... Manson" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-2077-17   STYLE OF CAUSE: ESCAPE TRAILER INDUSTRIES LTD v ATTORNEY GENERAL OF CANADA (THE MINISTER OF NATIONAL REVENUE)   PLACE OF HEARING: Vancouver, British Columbia   DATE OF HEARING: DECEMBER 17, 2018 JUDGMENT AND REASONS: MANSON J.   ...

REASONS FOR ORDER Owen J. [1]   Cameco Corporation (the “ Appellant ”) appealed reassessments (the “ Reassessments ”) of its taxation years ending December 31, 2003, December 31, 2005 and December 31, 2006 (collectively, the “Appeals”). ... The Respondent suggests that the Appellant has included in its total fees dockets for years other than 2003, 2005 and 2006. ... Analysis [5]   Subsections 147(1) to (3) and (4) to (5) of the Tax Court of Canada Rules (General Procedure) (the “ Rules ”) state: 147. ...

Wellsch Counsel for the Respondent: Jon Gilbert COUNSEL OF RECORD:        For the Appellant:                    Name:                              Hal B. Wellsch                    Firm:                                McCrank and Stewart Johnson                                                           Regina, Saskatchewan        For the Respondent:                     John H. ... Carr, ed., Canadian Resource Taxation, (Toronto: Carswell, 1999, 2005), at 8-7 to 8-8, and 8-31 to 8-32. [8] Paragraphs 8 and 9 of the Subscription and Renunciation Agreement; Schedule "A" to the Partial Statement of Agreed Facts. ...

From there he went to CIBC World Markets in about 2005. He described that when he left CIBC World Markets in 2007, he was its Head of Institutional Trading. ... The Queen, 2004 DTC 3090 (TCC) aff’d, 2005 DTC 5607 (FCA); McGroarty v. ... THE QUEEN   PLACE OF HEARING: Toronto, Ontario   DATES OF HEARING: August 25 and 26, 2016   REASONS FOR JUDGMENT BY: The Honourable Justice Patrick Boyle   DATE OF JUDGMENT: April 21, 2017   APPEARANCES:   Counsel for the Appellant: Peter Aprile Yoni Moussadji Counsel for the Respondent: Amit Ummat COUNSEL OF RECORD:     For the Appellant: Peter Aprile Yoni Moussadji   Firm: Counter Tax Lawyers Toronto, Ontario   For the Respondent: William F. ...

“Gaston Jorré” Jorré J.         Citation: 2020TCC57 Date: 20200716 Docket: 2015-3870(IT)G BETWEEN: RIKA LAVIGNE, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... In the circumstances, a few minutes into the hearing, I allowed the Appellant to make the late election- see subsection 18(1) of the Income Tax Act and Rule 16(1) of the Tax Court of Canada Rules (Informal Procedure). [2]   In the years 2004 to 2009 the Appellant reported on lines 162 and 135 of her tax returns gross and net business income of approximately: $185,000 and $74,000 in 2004; $140,000 and $41,000 in 2005, $115,000 and $24,000 in 2006, $124,000 and $11,000 in 2007, $180,000 and $17,000 in 2008 and $122,000 and $5,000 in 2009 – see pages 11 to 17 at Tab 41 of Exhibit R-2. [3]   The Income Tax Act empowers the Minister of National Revenue to carry out her functions through her agents. ...   [10]   See page 15 of Exhibit R-4. [11]   Exhibit R-4, page 18. [12]   One would expect her to have received a bill giving some indication as to what was being paid for. ...

Signed at Ottawa, Canada, this 12th day of January 2015.   “Lucie Lamarre” Lamarre J.     ... M.N.R., 2005 FCA 165). [55]         For these reasons, I am would allow the appeals. ...