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SCC

Symes v. Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40

Instead, she was rejecting both the need for a causal connection between a particular expenditure and a particular receipt, and the suggestion that a receipt must arise in the same year as an expenditure is incurred. ... Direct discrimination occurs in this connection where an employer adopts a practice or rule which on its face discriminates on a prohibited ground. ... Conclusion My incursion into section 15 of the Charter was mandated only by my colleague's comments in that connection. ...
SCC

Manitoba Metis Federation Inc. v. Canada (Attorney General), 2013 SCC 14, [2013] 1 SCR 623

(H.), discoverability was used to toll the limitation period until such time as the victim of childhood incest was able to discover “the connection between the harm she has suffered and her childhood history” (p. 35). ... Limitations law permits exceptions grounded in lack of knowledge of the facts underlying the claim and the connection between those facts, the actions of the defendant and the harm suffered by the plaintiff. [241]                       The Métis can make no such claim. ... Nor can they claim that they were unaware of the connection between the length of time that the distribution was taking and the actions of the government, since the trial judge found that the federal government responded to this 1872 complaint by reiterating that the selection and allocation of land was within the sole control of Canada. ...
FCTD

Bessette v. Quebec (Attorney General), 2019 FC 393

This presentation was made in 2015 by officials of the MSSS and RAMQ, in connection with the related file brought before the Superior Court of Quebec. ... This does not help me in view of the conclusions I have already drawn in connection with Mr.  ... April relies on his comments made in connection with claims 9 and 10 for claims 33 and 34, claims 3 and 4 for claims 35 and 36, and claims 13 and 14 for claims 39 and 40 (April Report, March 9, 2018, at paras 298-301). ...
TCC

Beaudry v. The Queen, 2010 DTC 1266 [at at 3853], 2008 TCC 17, aff'd Romar v. The Queen, 2010 DTC 5076 [at 6816], 2009 FCA 48

During the same fiscal year, CMRA issued 18 notes to Coral, denominated in Brazilian currency, in connection with the 40   Coral projects. ...        [24]     Before CMRA and CMRA 2’s contracts with Coral were signed, the partnerships' promoters did not approach any firms other than Coral in connection with the performance of the work contemplated in the contracts ... The Appellants set up research projects, but the great majority of the deductions that they claim have no connection with that research ...
TCC

GlaxoSmithKline Inc. v. The Queen, 2008 DTC 3957, 2008 TCC 324

Fisk made it clear that the price of the API had no connection to its manufacturing costs or to the costs of the generic products. ... There was no connection whatsoever between the two agreements. The respondent submits that this is further evidence that the two agreements were independent from one another ... Fisk 2002-04-30   1537     1534 ~ 1539 5 Y   There is a connection here as all questions relate to the French market and Fournier. 4.                    ...
SCC

Canadian Pacific Ltd. v. Matsqui Indian Band, [1995] 1 SCR 3

Hamilton, [1982] 1 All E.R. 1042, at p. 1046, an appellate court "must defer to the judge's exercise of his discretion and must not interfere with it merely on the ground that the members of the appellate court would have exercised the discretion differently".   40       I will consider four issues in connection with Joyal J.'s exercise of discretion pursuant to the adequate alternative remedy principle:   (i)Was it an error for Joyal J. to consider the policy considerations behind the assessment by-laws in determining how his discretion should be exercised?   ... Lippé, supra, Rousseau-Houle J.A., writing for the Court of Appeal, considered (i) the statutory scheme on its face; (ii) the actual appointment terms (at p. 664), financial security (at p. 666), and connection to the executive branch of government (at pp. 668-71) for each of the individual lay members of the Competition Tribunal; and (iii) the administrative policy respecting, inter alia, remuneration of tribunal members (at p. 668).   121              In the human rights context, in MacBain v. ... In finding a reasonable apprehension of institutional bias where there was a direct connection between the Commission as prosecutor and appointment of the tribunal which heard the case, Heald J. noted the importance of both the scheme of the legislation and how that legislation operated in practice (at p. 872):   I think it clear from this passage that in the view of Collier J. a "properly informed person" was one who was knowledgeable about the scheme of the statute and was also knowledgeable as to the way in which that scheme was applied in the processing of the complaint at bar.  ...
TCC

Farm Credit Canada v. The Queen, 2017 TCC 29

The loans chosen were those that had a direct connection with the province: loans secured by land in the participating province; loans, not secured by land, made to residents of the province; and certain loans administered by the entity`s employees in the province. [152]                   Clearly, section 11 of the Old Attribution Regulations (and section 26 of the New Attribution Regulations) is attempting to estimate consumption for entities whose principal business is the lending of money. [153]                   In my view, the foregoing textual, contextual and purposive analysis, particularly the examination of the definition of SLFI in paragraphs 149(1)(a)(i) to (x), of the wording of section 11 of the Old Attribution Regulations and of the structure of Part II of the Attribution Regulations, leads to the conclusion that the words “ loan corporation ” as used in section 11 of the Old Attribution Regulations (and section 26 of the New Attribution Regulations) refer to a corporation whose principal business is the lending of money. [154]                   An entity such as the Appellant is only included in the SAM Rules because its principal business is the lending of money. ... Interest on various instruments   (4)  For the purpose of subsection (2), “gross revenue” does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations of the financial institution.   ... Interest on various instruments   (4)  For the purpose of subsection (2), gross revenue does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations of the financial institution.   ...
FCTD

Canada (National Revenue) v. Shopify Inc., 2025 FC 969

Finding the UPR overly broad, Justice Roy held that “[when] the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition” (Hydro-Québec #1 at para 78). ... (b), Exhibit “B” – “Draft requirement”). [76] Shopify argues that this inconsistency renders the Proposed UPR unworkable, because it is unclear what connection to a “Canadian address” is necessary for the purposes of inclusion in the target group. ... On this evidence, Justice McDonald found that the Minister had demonstrated a sufficient connection between the content of the requirement and its stated purpose (Helcim at para 27). ...
FCTD

Mitchell v. Canada (Minister of National Revenue), docket T-434-90

He stated that:          The Mohawks, of course, established a very close connection with whatever European power dominated the Hudson Valley. ... The English trader Robert Sanders, in 1753, was aware that his French Canadian connections were being pressured to cease their trade with the English. So he sent letters of account back to his French connections with their names designated by a pictorial code which only he and his Mohawk traders knew. ...
SCC

Ontario Home Builders' Association v. York Region Board of Education, [1996] 2 SCR 929

Although the charge is attached to the cost of purchasing a building permit, that appears to be for administrative convenience rather than any real connection to the construction of a house.   ... However, in the early 1930s the higher courts were again faced with the issue in a series of cases dealing with the constitutionality of levies imposed by the provinces in connection with marketing schemes.  ... As my colleague La   Forest J. noted in his study of the taxation power under the Canadian Constitution, “ the person who ultimately pays an excise tax may have no other connection with the province benefiting from the tax than that the product was originally produced or manufactured there ” (G. ...

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