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TCC

Exxonmobil Canada Ltd. v. The Queen, 2019 TCC 108

ExxonMobil Canada Hibernia Company Ltd. claimed for income tax purposes, that the following work for RCA resulted in scientific and technological advancements, which was accepted by the Minister for the 2005 taxation year: i)   integration of aquifer data at regional and field scales; ii)   study of the role of intermediate structural blocks in dual fluid separation; iii)   gravity segregation of oil; iv)   integration of RCA prediction as first-order predictor to focus Direct Hydrocarbon Indicator studies; and v)   visualization using Petrel 3D models to evaluate plausible connections and spill/breakover points. 71.   ...
TCC

AE Hospitality Ltd. v. M.N.R., 2019 TCC 116

This Agreement may be assigned by the Company in connection with a merger or sale of all or substantially all of its assets, and in other instances with the Independent Contractor’s consent, which consent shall not be unreasonable withheld or delayed. […] [Emphasis added.] ...
FCTD

Glatt v. Canada (National Revenue), 2019 FC 738

The Respondent counters that there is no connection between the statute’s provisions related to the Minister’s charging, and refunding of interest.   ...
FCTD

Live! Holdings, LLC v. Oyen Wiggs Green & Mutala LLP, 2019 FC 1042

Although there were no bricks and mortar retail stores in Canada, Justice Simpson found that the website services were akin to visiting a retail store and benefitted people in Canada (TSA Stores, at paras 19-21). [72]   Justice Simpson stated at para 21, “[a]ccordingly, since the Marks appear in connection with these ancillary retail store services on the Website, I have concluded that there is evidence of use in Canada in the Relevant Period.” [73]   In Dollar General, Justice Manson allowed the appeal of the Registrar’s decision which had expunged the trade-mark for use in association with “retail store services”. ...
FCTD

Canada (Public Safety and Emergency Preparedness) v. Hamdan, 2019 FC 1129

Thus, each condition must have a rational connection to the circumstances of the case and the specific ground of detention, which the Board member should explain in the reasons. [68]   The Guidelines, of course, take into account the guidance provided by the law and jurisprudence that has come out of it, which require the ID to be vigilant when a danger has been found. [69]   Here, the Member was alive to the ‘danger’ evidence.   ...
TCC

Stark International Inc. v. The Queen, 2019 TCC 248

Property used to manufacture or process goods to be supplied in connection with the provision of a service, namely through a contract for work and materials, is not viewed as being used directly or indirectly in Canada primarily in the manufacturing or processing of goods for sale, and as such, does not qualify for either the accelerated capital cost allowance or the investment tax credit…. ...
FCTD

Canada (Information Commissioner) v. Canada (Public Safety and Emergency Preparedness), 2019 FC 1279

The importance of privacy rights is such that unauthorized release of personal information should be avoided, even if only some members of the public could draw the connections that would link the information to an identifiable individual. [63]   An example will help illustrate the concern. ...
TCC

Indusol Industrial Control Ltd. v. The Queen, 2020 TCC 103

The Minister denied the deduction of the said expenses as well as the investment tax credit (“ ITC ”) of $49,224 claimed in connection with those expenses. [3]   At the hearing, Mr.  ...
FCTD

Rémillard v. Canada (National Revenue), 2020 FC 1061, aff'd 2022 CAF 63

Evidence relating to taxpayer information Communication de renseignements dans le cadre d’une procédure judiciaire   (2) Notwithstanding any other Act of Parliament or other law, no official or other representative of a government entity shall be required, in connection with any legal proceedings, to give or produce evidence relating to any taxpayer information. (2) Malgré toute autre loi ou règle de droit, nul fonctionnaire ou autre représentant d’une entité gouvernementale ne peut être requis, dans le cadre d’une procédure judiciaire, de témoigner, ou de produire quoi que ce soit, relativement à un renseignement confidentiel.   ...
TCC

Anderson v. M.N.R., 2021 TCC 28

John, a laptop computer, computer software (including software customized for insurance adjusters), an internet connection, utilities and office supplies. [43] Mr. ...

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