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LASKIN J.A.   BETWEEN:     ALEXEY LAVRINENKO     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard at Toronto, Ontario, on October 4, 2018. ... LASKIN J.A.   BETWEEN:     ALEXEY LAVRINENKO     Appellant     and     HER MAJESTY THE QUEEN     Respondent   REASONS FOR JUDGMENT WEBB J.A. [1]   This is an appeal from the judgment of Justice Paris (2017 TCC 230) that dismissed Mr.  ... The Queen, 2005 SCC 54, [2005] 2 S.C.R. 601, at para. 10, the Supreme Court of Canada set out the approach to be used in interpreting provisions such as the one in issue in this appeal: 10   It has been long 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": see 65302 British Columbia Ltd. v. ...

GOYETTE J.A.   BETWEEN:     NORTHBRIDGE COMMERCIAL INSURANCE CORPORATION     Appellant     and     HIS MAJESTY THE KING     Respondent   Heard at Toronto, Ontario, on December 14, 2022. ... GOYETTE J.A.   BETWEEN:     NORTHBRIDGE COMMERCIAL INSURANCE CORPORATION     Appellant     and     HIS MAJESTY THE KING     Respondent   REASONS FOR JUDGMENT WEBB J.A. [1] Northbridge Commercial Insurance Corporation (Northbridge) issued insurance policies to trucking companies that operated in Canada and the United States. ... Canada, 2005 SCC 54, at para. 10). The role of this Court is to determine the interpretation of the provision in issue that was intended by Parliament. ...

Canada, 2004 FCA 403, [2005] 1 C.T.C. 212 at para. 7). Abuse of process is a flexible doctrine, based on the idea that a court has an inherent discretion to terminate litigation at the preliminary stage in order to prevent abusive proceedings that bring the administration of justice into disrepute (Timm v. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Edmonton, Alberta   DATE OF HEARING: December 4, 2017   REASONS FOR JUDGMENT BY: LASKIN J.A.   ... NEAR J.A.   DATED: December 15, 2017   APPEARANCES: Mark Lynch   For The Appellant (on his own behalf)   Mark Heseltine   For The Respondent   SOLICITORS OF RECORD: Nathalie G. ...

Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at para. 10. [43]            Nevertheless, a court must consider the total context of the provision to be interpreted “no matter how plain the disposition may seem upon initial reading”: ATCO Gas and Pipelines Ltd v. ... CANADA (MINISTER OF PUBLIC SAFETY AND EMERGENCY PREPAREDNESS)     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: September 22, 2017   REASONS FOR JUDGMENT BY: STRATAS J.A.   ... WEBB J.A.   DATED: DECEMBER 28, 2017   APPEARANCES: Leo Salloum   For The Appellant   Jacob Pollice   For The Respondent SOLICITORS OF RECORD: Grill Barristers Toronto, Ontario   For The Appellant   Nathalie G. ...

WALKER J.A.     BETWEEN: HIS MAJESTY THE KING Appellant and ROBERT MARCUS HIRSCHFIELD Respondent Heard at Vancouver, British Columbia, on April 16, 2024. ... WALKER J.A.     Date: 20250122 Docket: A-182-23 Citation: 2025 FCA 17 CORAM: DE MONTIGNY C.J. ... WALKER J.A.     BETWEEN: HIS MAJESTY THE KING Appellant and ROBERT MARCUS HIRSCHFIELD Respondent REASONS FOR JUDGMENT LASKIN J.A. ...

BETWEEN:   MINISTER OF NATIONAL REVENUE   Appellant   and   CONOCOPHILLIPS CANADA RESOURCES CORP.   ... Canada, 2005 FCA 393, 344 N.R. 169, at paragraphs 11 to 13. It is open to ConocoPhillips to request that the question of the timeliness of its notice of objection be determined before the trial pursuant to Rule 58(1) of the Tax Court of Canada Rules (General Procedure), SOR/90-688a. [9]                At paragraph 8 of his reasons, the Federal Court Judge expressed the view that paragraph 169(1)(b) of the Act did not apply because “the conditions precedents [sic] do not exist”. ...

HER MAJESTY THE QUEEN     PLACE OF HEARING: Calgary, Alberta   DATE OF HEARING: March 31, 2022   REASONS FOR JUDGMENT OF THE COURT BY: STRATAS J.A. ... LOCKE J.A.   DELIVERED FROM THE BENCH BY: DE MONTIGNY J.A. APPEARANCES: Rumi Vesuna   For The Appellant ON THEIR OWN BEHALF   Courtney Davidson   For The Respondent   SOLICITORS OF RECORD: A. François Daigle Deputy Attorney General of Canada For The Respondent                 ...

The Judge granted a motion brought by Her Majesty the Queen (the “Crown”), pursuant to Rules 95 and 110 of the Tax Court of Canada Rules (General Procedure), S.O.R./90-688a (the “ Tax Court Rules ”), for an order compelling Buhler Versatile Inc. (the “Taxpayer”) to produce five binders of documents (the “Five Binders”). [2]                The dispute arose in the context of the Taxpayer’s appeal from an assessment, pursuant to the Income Tax Act, R.S.C. 1985, c. 1 (5 th Supp.), dated December 2, 2008 (the “Assessment”), which disallowed the Taxpayer’s claim for certain scientific research and experimental development expenditures and investment tax credits in respect of the Taxpayer’s 2005 taxation year. [3]                In an attempt to persuade the Canada Revenue Agency Appeals Division (the “Appeals Division”) to vary or vacate the Assessment, the Taxpayer made a lengthy submission to it by correspondence dated October 21, 2011. ... Pentney Deputy Attorney General of Canada For The Respondent   ...

BOIVIN J.A.   BETWEEN: SIRUS FAMILAMIRI Appellant and HER MAJESTY THE QUEEN Respondent Heard at Vancouver, British Columbia, on March 14, 2016. ... E-15 (the "Act") with respect to the Taxpayer’s reporting period between January 1, 2005 and December 31, 2010 (the "Period"). [2]                The Reassessment imposed net goods and services tax ("GST") and harmonized sales tax ("HST"), in the amount of $22,950, and certain penalties on the Taxpayer on the basis that he had failed to collect GST and HST on the amounts that were paid to him by 494743 B.C. ... Pentney Deputy Attorney General of Canada Ottawa, Ontario For The Respondent   ...

REASONS FOR JUDGMENT OF THE COURT BY: RYER J.A.   Date: 20160314 Docket: A-9-15 Citation: 2016 FCA 85 CORAM: RYER J.A. ... This we cannot do. [9]                Accordingly, the appeal will be dismissed without costs. ... Pentney Deputy Attorney General of Canada Ottawa, Ontario For The Respondent   ...