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Results 431 - 440 of 1092 for connection
FCTD
Davidson v. Canada (Attorney General), 2019 FC 997
The Applicant then sent the Investigator an email on March 26, 2018, with records prepared by him on the files he worked on at GAC. [8] Materially on the issue of procedural fairness, the Investigator interviewed two GAC officers in connection with certain case management tracking documents maintained by GAC on ATIP files worked on by the Applicant in 2013. ... The general principles regarding the content of the duty of fairness in this connection are set out in Re: Sound, where the Federal Court of Appeal states: [54] However, agencies must ensure that, if they obtain information from third parties, they do not thereby jeopardize parties’ participatory rights: to know and to comment on material relevant to the decision; to have notice of the grounds on which the decision may be based; and to have an opportunity to make representations accordingly. ... [Emphasis added] [33] In this connection and before the hearing, the following direction was sent to the parties alerting counsel of the importance of this issue: The Court has questions regarding the 131 pages of documents in the Supplementary Certificate dated 29 November, 2018, stated to be contained in the “Commission’s investigation file” in respect of the Applicant’s complaint. ...
FCTD
Adey v. Canada (Attorney General), 2019 FC 1001
Some Applicants did submit T626s, and some OETCs were granted but then clawed back with interest. [7] In October 2009, a CNA-Q employee filed an appeal of a denial of the OETC, but this appeal was denied by the Tax Court of Canada [the Tax Court] in May 2010 in Humber v The Queen, 2010 TCC 253, in part based on the Court’s conclusion that the appellant had failed to lead sufficient evidence to show a connection between the training provided by CNA-Q and the oil and gas industry in Qatar. ... The CRA has adopted this policy consideration in connection both with requests made during the taxpayer’s normal reassessment period and with requests applicable to statute-barred years. [20] The Applicants observe that the both the Decisions and the Taxpayer Relief Fact Sheets in the record which serve as background to the Decisions demonstrate that, for most of the Applicants, the Delegate concluded that the Legge decision was not the sole factor underlying the requests for adjustments, although it was a significant factor or indeed the main factor. ... While it may have been available to the Delegate to depart from the policy based on the Applicants’ circumstances, I find no basis for a conclusion that the Delegate’s decision not to do so is outside the range of acceptable outcomes based on the facts and law applicable to these matters. [34] Finally, in connection with the Applicants’ submission that the Delegate slavishly applied the policy considerations canvassed above, I note the Respondent’s argument that, in relation to six of the Applicants, the Delegate allowed adjustment requests applicable to statute-barred years, because the Applicant had not been advised by the CRA of certain recourse rights. ...
FCTD
Canada (National Revenue) v. Friedman, 2019 FC 1583, aff'd 2021 FCA 101
In order to expedite and facilitate our audit, we will require a clear understanding of all entities with which you had a connection or affiliation during the taxation years noted above. ... The words “connection” or “affiliation” in this letter are to be given their ordinary meaning versus any restricted definitions set out in the Income Tax Act. ... The Friedmans contend that the logic applied in Lin applies equally in the present case. [30] The Friedmans also say that the second paragraph of the letters, which read “[i]n order to expedite and facilitate our audit, we will require a clear understanding of all entities with which you had a connection or affiliation during the taxation years noted above”, changes the scope of the motion, as the CRA is asking for documents from all of the Friedmans’ related entities. ...
FCTD
Simmons v. Canada (Attorney General), 2021 FC 202
This letter will be considered further below. [27] As noted, in his submissions in connection with the reconsideration, Mr. ... Simmons’s request for relief. [38] In connection with this fourth review, by letter dated January 25, 2019, the CRA requested the following additional information from Mr. ... Simmons in connection with the reconsideration (in April 2018 and again in March 2019) do not address them either (apart from the boilerplate statement that all previous materials were being relied upon). ...
FCTD
Seaspan International Ltd. v. Her Majesty the Queen, [1993] 2 CTC 307
The usefulness of this case, as was pointed out by the Tax Review Board in the McLean case at page 121, supra, is diminished by the fact that the Court only considered the meaning of “ vehicle” in connection with specific words of the Act in issue, being "a vehicle on the public highway”. ... In this connection, it is in evidence that when the Excise Tax Act was being debated in Parliament, the Minister, the Honourable M. ... It was our intention to eliminate it in connection with diesel fuel used for transportation. ...
FCTD
Rémillard v. Canada (National Revenue), 2021 FC 644
Rémillard ’s argument in this regard is that he focuses too much on what information will or will not establish his connection to Canada rather than what information will support or address the allegations in his notice of application, that is, information that can shed light on whether the Foreign Requests are reasonable or unreasonable. It is really this latter issue that is the subject of the underlying application for judicial review, and it is this issue that the Minister had in mind when she decided to disclose the information, not whether the information establishes a connection between Mr. ... On the contrary, their identities and the connections between them and Mr. ...
FCTD
Iris Technologies Inc. v. Canada (National Revenue), 2021 FC 874
Iristel fails to establish a connection between these past claimed harms and the claim being made about future irreparable harm. [58] For example, in Mr. ... This is a claim of retrospective harm and no connection is established on the evidence between that claim and the claim of future irreparable harm if the relief sought is not granted prior to a determination on the underlying judicial review application. [59] Other claims advanced are speculative and based on an insufficient record that requires the Court to make a number of inferences which are not in evidence. ... The Court has not been furnished with clear evidence as to the Iristel's requirement for credit from banks or private lenders, or the connection between its status with creditors and other potential lenders and the claim of future irreparable harm. [63] The Applicant argues that if the motion is not granted, it will “end Iristel” and “endanger the more than 7 000 000 Canadians who rely on Iristel and its services.” ...
FCTD
Christen v. Canada (Revenue Agency), 2021 FC 1440
Roy, who is a central figure in connection with the Decision, and gives rise to a reasonable apprehension of bias on the part of the respondent in connection with the Decision. [53] In addition, the process leading to the First Decision is deficient mainly because of the notorious email from Ms. ... Henderson’s email is indicative of neither bad faith nor bias on the part of the VDP in connection with the Decision contested in this application for judicial review. ...
FCTD
National Council of Canadian Muslims v. Canada (Attorney General), 2022 FC 324
Other members of the public may also be more generally interested in the outcome of any proceeding regarding judicial conduct. [83] The CFE and CAUT and B’nai Brith have all established their genuine interest in the matter before the Court and have the knowledge and experience on the issues they propose to address in their submissions (Council of Refugees at para 6). [84] As Justice Rennie explained in Gordillo at para 12, there must be a connection between the issue to be decided and the mandate and objectives of the proposed intervener. ... There must be more than a “jurisprudential” interest in the legal question alone. [85] The connection between the CFE and CAUT—with their focus on academic freedom—and the issue of the reasonableness of the CJC’s decision is the context underlying the complaints. ... The CFE and CAUT have a perspective and experience on academic freedom, which is the context for the conduct underlying the complaints. [86] The connection between B’nai Brith—with its focus on the issue of the apprehension of bias based on affiliation—and the issue of the reasonableness of the CJC’s decision is also related to the context for the conduct underlying the complaints. ...
FCTD
Hébert Estate v. Canada (Attorney General), 2021 FC 1076
Guillemette in connection with paragraphs 10, 20, 37 and 38 of Ms. Hamel’s affidavit). ... Guillemette’s affidavit). [24] Further, in connection with the Notice of Objection, the system notes reveal that on January 29, 2019, the officer in charge of the objection had communicated with Ms. ... Hamel communicated her submissions, again in connection with her objection. ...