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Results 521 - 530 of 534 for connection
FCA
Alliance For Life v. Canada (Minister of National Revenue), 99 DTC 5228 (FCA)
In this same connection, Iacobucci J. added the following at paragraph 158: The chief proposition to be drawn from this holding is that even the pursuit of a purpose which would be non-charitable in itself may not disqualify an organization from being considered charitable if it is pursued only as a means of fulfilment of another, charitable, purpose and not as an end in itself. ... The learned author opined in this same connection that "there is little doubt that, if the genuine and sole object is to enlighten the public on the theories and concepts of political belief in general, this is educational". ...
FCA
HEILTSUK HORIZON MARITIME SERVICES LTD. v. ATLANTIC TOWING LIMITED et al. AND DOCKET: A-57-19 STYLE OF CAUSE: HEILTSUK HORIZON MARITIME SERVICES LTD. et al. v. ATLANTIC TOWING LIMITED et al. AND DOCKET: A-428-19 STYLE OF CAUSE: ATLANTIC TOWING LIMITED v. HEILSTUK HORIZON MARITIME SERVICES LTD. et al. AND DOCKET: A-430-19 STYLE OF CAUSE: HEILTSUK HORIZON MARITIME SERVICES LTD. v. ATLANTIC TOWING LIMITED et al. AND DOCKET: A-433-19 STYLE OF CAUSE: ATTORNEY GENERAL OF CANADA v. HEILTSUK HORIZON MARITIME SERVICES LTD. et al., 2021 FCA 26
Heiltsuk Horizon ranked last. [3] Heiltsuk Horizon, which filed four complaints with the Tribunal in connection with the Solicitation, as permitted by the Canadian International Trade Tribunal Act, R.S.C. 1985, c. 47 (4th Supp.) ... Heiltsuk Horizon explained at the hearing that it had made a strategic choice not to file reply evidence with respect to the New Evidence based on its understanding that vessel substitution was permitted by the RFP. [185] Whether this view is supported by the terms of the RFP need not be decided here in light of my findings on the merits of all five applications for judicial review, which seal the fate of Heiltsuk Horizon’s four complaints filed with the Tribunal in connection with the Solicitation. [186] In sum, I see no reason to award costs to Atlantic on a solicitor-client basis. ...
FCA
Alliance for Life v. Minister of National Revenue, [1999] 3 CTC 1
In this same connection, lacobucci J. added the following at paragraph 158: The chief proposition to be drawn from this holding is that even the pursuit of a purpose which would be non-charitable in itself may not disqualify an organization from being considered charitable if it is pursued only as a means of fulfilment of another, charitable, purpose and not as an end in itself. ... The learned author opined in this same connection that “there is little doubt that, if the genuine and sole object is to enlighten the public on the theories and concepts of political belief in general, this is educational”. ...
FCA
Canada v. Bombardier Inc., 2012 DTC 5088 [at at 7005], 2012 FCA 46
., quoted above in connection with the percentage‑of‑completion method ...
FCA
Canada (National Revenue) v. JP Morgan Asset Management (Canada) Inc., 2014 DTC 5001 [at at 6501], 2013 FCA 250
[32] Almost always, applications for judicial review of administrative actions by the Minister in connection with assessments fail, especially in this Court. ...
FCA
Canadian Magen David Adom for Israel v. Canada (Minister of National Revenue), 2002 DTC 7353, 2002 FCA 323
It is also the first express explanation of the connection between the absence of an agency agreement and the failure to meet the disbursement quota. ...
FCA
St. Michael Trust Corp. v. Canada, 2010 DTC 5189 [at at 7361], 2010 FCA 309, aff'd sub nom Fundy Settlement v. Canada, 2012 DTC 5063 [at 6881], 2012 SCC 14
For example, in the case of an individual, the relevant factors could include nationality, physical presence, location of the family home, location of business and social interests, mode of family life, and social connections through birth or marriage (a more detailed list of specific factors can be found in Krishna, at pages 88-91). ...
FCA
Loewen v. The Queen, 94 DTC 6265, [1994] 2 CTC 75 (FCA)
The nearest parallel to the present case is the decision in Moloney, supra, where there was no profit, but a purported expense incurred in connection with a tax avoidance scheme was disallowed. ...
FCA
Canada v. Garber, 2008 FCA 53
[footnote omitted] It is noteworthy in this connection that in those cases where the doctrine of abuse of process has been applied to prevent relitigation, it is invariably the party that lost the first litigation that seeks to gain through the relitigation. ...
FCA
Dwyer v. Canada, 2003 FCA 322
Apart from a clear decision to pursue a criminal investigation, no one factor is necessarily determinative in and of itself, but courts must assess the totality of the circumstances, and make a determination as to whether the inquiry or question in issue engages the adversarial relationship between the state and the individual. 94 In this connection, the trial judge will look at all factors, including but not limited to such questions as: (a) Did the authorities have reasonable grounds to lay charges? ...