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TCC

Black v. The King, 2024 TCC 96

Do all things as directed by the Committee in connection with the granting, vesting or termination of Rights in accordance with the Plan iii. ...
TCC

Garber v. The Queen, 2014 DTC 1045 [at at 2812], 2014 TCC 1

d)     The investor’s agreement to grant OCGC Power of Attorney and to appoint OCGC as his agent and true and lawful attorney for purposes in connection with the S/Y Close Encounters LP.   ... Scace to assess whether the financing transactions with Neptune Marine Resources S.A. in connection with the manufacturing of yachts and the provision of services relating to the yacht chartering/luxury cruise business had, in fact, taken place. ... Justice Woods went on to conclude that the evidence pointed to the entire transactions being a scam, and therefore, without a sufficient connection between a genuine business and the losses claimed, the losses were barred from deductibility. ...
FCTD

Benoit v. Canada, 2002 FCT 243

" Page 60      mr. mckenna: "The third year was only mentioned in connection with clothing. ... Beaulieu also commented that later, "[a] certain number of Indians thought that property owned outside of reservations was exempt from taxation" (Transcript, 11 July 2001, 3185). [128]        As to the connection between tax exemption and treaty rights, Dr. ... Opekokew testified that: she is a Saskatchewan lawyer who has practised law since 1979; Cree is her first language, English is her second; as a result of an uncompleted attempt by the Minister of Indian Affairs to review Treaty 8 in the 1980's, the Grand Council of Treaty 8 received a grant from the Government of Canada to investigate the meaning of Treaty 8; as part of this investigation she conducted some 30 interviews with elders identified by the leaders of the funded organization; the interviews were conducted according to guidelines established in the case law at the time, one of which was to ensure that her questions of the elders touched on the history or the connection that the elder had to the direct witnesses that had been present at the time of the treaties; Mr. ...
SCC

Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65, [2019] 4 SCR 653

Post‑ Dunsmuir, the Court has been steadfast in confirming the central role of specialization and expertise, affirming their connection to legislative intent, and recognizing that they give administrative decision-makers the interpretative upper hand on questions of law. ... There is no purpose served in excluding any child born of a person not having a connection to a diplomatic mission in Canada while sojourning here from the principle of Jus soli.    ... Post- Dunsmuir, the Court has been steadfast in confirming the central role of specialization and expertise, affirming their connection to legislative intent, and recognizing that they give administrative decision-makers the “interpretative upper hand” on questions of law (McLean, at para. 40; see also Conway, at para. 53; Mowat, at para. 30; Newfoundland and Labrador Nurses’ Union v. ...
TCC

Univar Canada Ltd. v. The Queen, 2005 DTC 1478, 2005 TCC 723

They had connection to the transactions or the arrangements that were in place relative to making sure we were in qualifications for the rules and regulations on the NEWCO structure.  ...
SCC

Century Services Inc. v. Canada (Attorney General), 2011 DTC 5006 [at at 5511], [2010] 3 S.C.R. 379, 2010 SCC 60

It is appropriate for the courts to take such policy considerations into account, but only if it is in connection with a matter that has not been considered by Parliament. ...
TCC

Bioartificial gel technologies (Bagtech) inc. v. The Queen, 2013 DTC 1048 [at at 228], 2012 TCC 120, aff'd 2013 FCA 164 supra.

The Queen, [2003] 1 F.C. 447, in which the Court held that “simple ownership of a mathematical majority of shares by a random aggregation of shareholders in a widely held corporation with some common identifying feature (e.g. place of residence) but without a common connection does not constitute de jure control as that term has been defined in the case law” (at para. 36). ...
TCC

Alberta Printed Circuits Ltd. v. The Queen, 2011 DTC 1177 [at at 967], 2011 TCC 232

This test has had ample use in that connection by the Federal Court of Appeal and Tax Court of Canada in numerous cases, i.e., in Cundill, earlier referenced, [15] and in Petro‑Canada v. ...
SCC

Royal Bank of Canada v. Sparrow Electric Corp., 97 DTC 5089, [1997] 1 SCR 411

In this connection, I find two of the express covenants in Sparrow's contractual arrangements to be salient.  ...
TCC

Drozdzik v. The Queen, docket 98-1605(IT)G

He met the Appellant in the years 1989/1990 in connection with his dealings with a Category 'G' license issued by the Department of Fisheries and Oceans ("D.F.O. ...

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