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  [19]   GFP is seeking judicial review of these decisions.   III.   ... In taxation matters, as in this case, the case law is consistent regarding the importance of predictability for accountants: Canada Trustco Mortgage Co v Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at p 609; Altus Group Ltd v Calgary (City), 2015 ABCA 86 at para 28. ...   (3)   Discussion [53]   At the outset, it should be pointed out that this is an application for judicial review. ...

Canada (Justice), 2011 FC 61   Federal Court   Cour fédérale     Date: 20110119 Docket: T-424-10 Citation: 2011 FC 61 [ENGLISH TRANSLATION] BETWEEN:   DANIEL JOLIVET       Applicant   and       THE MINISTER OF JUSTICE CANADA   and   THE CRIMINAL CONVICTION REVIEW GROUP         Respondents         REASONS FOR ORDER: PROTHONOTARY MORNEAU   [1] At issue in this case is deciding, under subsections 318(3) and (4) of the Federal Courts Rules (the Rules), and in accordance with the direction of this Court on July 22, 2010, on the merits of the objection raised by the respondents under subsection 318(2) of the Rules. [2] This objection was made pursuant to a request for transmission of material by the applicant under subsections 317(1) and (2) of the Rules within the framework of his application for judicial review filed on March 22, 2010 (the application for review). [3] This request for transmission of material is, as shall be demonstrated, rather long and covers almost five (5) pages in the application for review. ... The CD-ROM forwarded to the CCRG on February 20, 2006 pursuant to the request of October 27, 2005. ... “Richard Morneau” Prothonotary   Montréal, Quebec January 19, 2011 FEDERAL COURT   SOLICITORS OF RECORD     DOCKET:   T-424-10   STYLE OF CAUSE:   DANIEL JOLIVET   and   THE MINISTER OF JUSTICE CANADA   and   THE CRIMINAL CONVICTION REVIEW GROUP   PLACE OF HEARING:   Montréal, Quebec   DATE OF HEARING:   January 12, 2011   REASONS FOR ORDER:   PROTHONOTARY MORNEAU   DATED:   January 19, 2011     APPEARANCES:   Lida Sara Nouraie   FOR FOR THE APPLICANT Jacques Savary   FOR THE RESPONDENTS   SOLICITORS OF RECORD:   Desrosiers, Joncas, Massicotte Montréal, Quebec   FOR FOR THE APPLICANT Myles J. ...

Lucia. [6]   In July 2005, Ms. Avril entered Canada with her older sister, Vernatta Avril, as visitors. ... Lucia as early as 2005. The Officer added that there was no way to verify who wrote the letters or to determine when they were received. ... DATED: November 27, 2019   APPEARANCES: Anthony Navaneelan   For The Applicant   Christopher Ezrin   For The Respondent   SOLICITORS OF RECORD: Refugee Law Office Legal Aid Ontario Barristers and Solicitors Toronto, Ontario   For The Applicant   Attorney General of Canada Toronto, Ontario   For The Respondent     ...

He has held this position since June 2005. [11]            The applicant has been married to a Canadian citizen since 1999, with whom he has seven children, all Canadian citizens. ... IV.              Issues and standard of review [40]            This application for judicial review raises the following issues: A.                 ... [53]            I agree with the respondent that the role of this Court is not to decide whether, on the evidence before the officer, there were “reasonable grounds to believe” that the essential elements of section 37 were satisfied, but only whether it was reasonable for her to conclude that there were (Canada (Minister of Citizenship and Immigration) v Thanaratnam, 2005 FCA 122 at paragraphs 32-33). [54]            The issue of whether there are “reasonable grounds to believe” that an event occurred within the meaning of section 33 of the IRPA requires more than mere suspicion, but the standard of proof is less onerous than that of the preponderance of the evidence. ...

Justice Near     BETWEEN:   NAZAR AHMAD, HAMIDUL AMEEN, PAMELA CHEUNG, HARJINDER DHESY, NORINE GOODMAN, DEBORAH HAIRE, ANDY HENDERSON, YULIA HIDIJAT, FANNY JANG, JULIAN LEBOFSKY, RICHARD MALONE, ANNA MICHIELI, CHRISTINE NG, NELLY NG, INDRAJIT ROY, SUSAN TIERNEY, CHELLIAH VENOGOPAL, SALIM VIRJI, FRANK WONG, HELEN YI, ANNA YU, AND RANDY ZURIN       Applicants   and       CANADA REVENUE AGENCY         Respondent                    AMENDED R EASONS FOR JUDGMENT AND JUDGMENT   [1]                This application for judicial review comprises 22 consolidated applications for judicial review concerning decisions made by Paul Loo in his capacity as a Decision Reviewer at the Canadian Revenue Agency (CRA).  ... As the Applicants submit, the Respondent has committed a reviewable error in failing to abide by its own procedures (Gilchrist v Canada (Treasury Board), 2005 FC 1322, 281   FTR 135 at para 13).   ...       “ D. G. Near ” Judge FEDERAL COURT   SOLICITORS OF RECORD       DOCKET:                                          T-2132-09   STYLE OF CAUSE:                          CHRISTINE NG ET AL. v. ...

The Minister relies on a 2005 FCA decision, Canada (Customs and Revenue Agency) v Artistic Ideas Inc., 2005 FCA 68 (Artistic Ideas), and line of cases from this Court adopting the Artistic Ideas interpretation of section 231.2. [32] I am not persuaded by Zeifmans’ submissions. ... "Elizabeth Walker" Judge   FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-400-19   STYLE OF CAUSE: ZEIFFMANS LLP v THE MINISTER OF NATIONAL REVENUE   PLACE OF HEARING: HELD BY VIDEOCONFERENCE FROM Concord, Ontario, Toronto, Ontario AND OTTAWA, ONTARIO   DATE OF HEARING: September 21, 2020   JUDGMENT AND REASONS: WALKER J.   DATED: APRIL 26, 2021   APPEARANCES: Dominic Marciano Raphael Rutman For The Applicant   Margaret McCabe Rita Araujo Jesse Epp-Fransen   For The Respondent   SOLICITORS OF RECORD: Marciano Beckenstein LLP Barristers and Solicitors Concord, Ontario   For The Applicant   Attorney General of Canada Toronto, Ontario   For The Respondent     ...

However, consistent with well-established precedent, the parties agree that the report prepared by the investigator dated June 26, 2017, forms part of the reasons for the decision (Sketchley v Canada (Attorney General), 2005 FCA 404 at paras 37-38). [15]   After reviewing some preliminary matters pertaining to the procedures followed by the Commission after it receives a complaint, the substance of the investigative report begins with the observation that, based on a review of the information provided by the parties, Mr. ... V.   ANALYSIS [24]   The Commission performs an important screening function.   ... DATED: September 12, 2019   APPEARANCES: Jennifer Zdriluk Wade Poziomka   For The Applicant   Gerald Griffiths   For The Respondent   SOLICITORS OF RECORD: Ross & McBride LLP Law Firm Toronto, Ontario   For The Applicant   Sherrard Kuzz LLP Employment & Labour Lawyers Toronto, Ontario   For The Respondent     ...

II.   Issues and Standard of Review [16]   The Applicants raise two issues.   ... These choices lie in the court of the Minister – not in mine.   Nor do I have the role to reweigh those considerations, and any others she felt were relevant to the public interest (see Sumas Energy 2 Inc v Canada (National Energy Board), 2005 FCA 377 at paras 23–25). 4.   ... VI.   Costs [74]   Both the Applicants and the Minister seek costs.   ...

Canada Revenue Agency, 2011 FC 481   Federal Court   Cour fédérale Date: 20110421 Docket: T-1822-10 Citation: 2011 FC 481 [UNREVISED CERTIFIED ENGLISH TRANSLATION] Ottawa, Ontario, April 21, 2011 PRESENT:     The Honourable Madam Justice Bédard   BETWEEN:   JACQUES FERRON       Applicant   and       CANADA REVENUE AGENCY         Respondent                  REASONS FOR JUDGMENT AND JUDGMENT   [1]                This is an application for judicial review filed by Jacques Ferron (the applicant) under subsection 18(1) of the Federal Courts Act, R.S., 1985, c. ...   [4]                On March 5, 2007, the CRA sent the applicant a letter informing him that he had made excess contributions to his RRSP for the 2003 to 2005 taxation years and that these excess contributions were taxable. ... “Marie-Josée Bédard” Judge                                                                                                                                                    Certified true translation   Sebastian Desbarats, Translator   SOLICITORS OF RECORD     DOCKET:                                           T-1822-10   STYLE OF CAUSE:                           JACQUES FERRON v. ...

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.     ...