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FCTD

McLennan v. Canada (Attorney General), 2019 FC 1267

(a) inform the offender of the referral and review, and [EN BLANC/BLANK] (b) review the case, [EN BLANC/BLANK] and the Board shall cause all such inquiries to be conducted in connection with the review as it considers necessary. ...
FCTD

Bryan v. Canada (Citizenship and Immigration), 2019 FC 1347

He argues that this, in connection with the seven letters of support, supports his establishment in Canada. [17]   At the hearing, the Applicant’s counsel agreed with the Court that the letter from Northplex did not offer the Applicant a job and the letter only stated when he had worked for them. ...
FCTD

Kaya v. Canada (Citizenship and Immigration), 2019 FC 1519

[emphasis added] [31]   In connection with determinations under IRPA ss 96-98, the SIO must be sensitive to the Maldonado Principle that a refugee claimant’s testimony is presumed true and credible absent any reason to discount or disbelieve it: Maldonado, above at para 5. ...
FCTD

Robidoux v. Canada (Public Safety and Emergency Preparedness), 2020 FC 766

He submits that the evidence demonstrates that he has maintained a significant connection to the U.S. during his period of medical treatment despite his lengthy presence in Canada; that any failure to fully disclose his circumstances to the BSOs was inadvertent or arose due to his misunderstanding the BSOs’ questions; and that the BSOs were familiar with his circumstances as a result of his regular crossings. ...
FCTD

Perinpanayagam v. TSFA Processing Unit, 2020 FC 1111

This is a pure question of fact, and of course the Officer is entitled to draw inferences in this connection as happened here. [34]   Moreover, and as noted above, on judicial review I am instructed to take a respectful view of the Decision (Vavilov, at para 12), and when I do, I find support for the Officer. ...
FCTD

Scannar Industries Inc. (Receiver Of) v. R., [1996] 2 CTC 105, 96 DTC 6237

In the Proteus Contract, Scannar agreed to pay, and in fact paid, a research and development fee in the amount of $25,000,000, which was payable as to $17,700,000 by cheque, and as to $7,300,000 by delivery of a promissory note, in consideration for Proteus’ agreeing to carry on scientific research and experimental development on behalf of Scannar in connection with certain laboratory rapid diagnostic products. 8. ...
FCTD

Hickman Motors Limited v. Her Majesty the Queen, [1993] 1 CTC 36, 93 DTC 5040

In this connection, I note that there are deeming provisions in paragraph 88(1.1)(b) regarding deductibility in the subsidiary's hands in its deemed taxation year, and an assumption that during that year, it had sufficient income. ...
FCTD

Katherine Furfaro-Siconolfi v. The Queen, [1990] 1 CTC 33, [1990] 1 CTC 188, [1990] DTC 6237

S.C. 134, Toth, J. also had occasion to refer to academic opinion and case law in connection with an action for execution of a marriage contract by the wife following a decree of separation as to bed and board. ...
FCTD

Her Majesty the Queen v. Gicleurs Astra Ltée, [1987] 1 CTC 161

It may be noted at once, in connection with this overvaluation, that the defendant cannot rely on that here as it never made use of the provisions of section 46 of the Customs Act to request a new ruling or valuation; furthermore, what it allegedly overpaid is not the subject of a separate claim or of a counterclaim. ...
FCTD

Canada (National Revenue) v. Zhao, 2022 FC 1108

. … 225.2 (1) In this section, judge means a judge or a local judge of a superior court of a province or a judge of the Federal Court. (2) Notwithstanding section 225.1, where, on ex parte application by the Minister, a judge is satisfied that there are reasonable grounds to believe that the collection of all or any part of an amount assessed in respect of a taxpayer would be jeopardized by a delay in the collection of that amount, the judge shall, on such terms as the judge considers reasonable in the circumstances, authorize the Minister to take forthwith any of the actions described in paragraphs 225.1(1)(a) to 225.1(1)(g) with respect to the amount. (3) An authorization under subsection 225.2(2) in respect of an amount assessed in respect of a taxpayer may be granted by a judge notwithstanding that a notice of assessment in respect of that amount has not been sent to the taxpayer at or before the time the application is made where the judge is satisfied that the receipt of the notice of assessment by the taxpayer would likely further jeopardize the collection of the amount, and for the purposes of sections 222, 223, 224, 224.1, 224.3 and 225, the amount in respect of which an authorization is so granted shall be deemed to be an amount payable under this Act. (4) Statements contained in an affidavit filed in the context of an application under this section may be based on belief with the grounds therefor. (5) An authorization granted under this section in respect of a taxpayer shall be served by the Minister on the taxpayer within 72 hours after it is granted, except where the judge orders the authorization to be served at some other time specified in the authorization, and, where a notice of assessment has not been sent to the taxpayer at or before the time of the application, the notice of assessment shall be served together with the authorization. (6) For the purposes of subsection 225.2(5), service on a taxpayer shall be effected by (a) personal service on the taxpayer; or (b) service in accordance with directions, if any, of a judge. (7) Where service on a taxpayer cannot reasonably otherwise be effected as and when required under this section, the Minister may, as soon as practicable, apply to a judge for further direction. (8) Where a judge of a court has granted an authorization under this section in respect of a taxpayer, the taxpayer may, on 6 clear days notice to the Deputy Attorney General of Canada, apply to a judge of the court to review the authorization. (9) An application under subsection 225.2(8) shall be made (a) within 30 days from the day on which the authorization was served on the taxpayer in accordance with this section; or (b) within such further time as a judge may allow, on being satisfied that the application was made as soon as practicable. (10) An application under subsection 225.2(8) may, on the application of the taxpayer, be heard in camera, if the taxpayer establishes to the satisfaction of the judge that the circumstances of the case justify in camera proceedings. (11) On an application under subsection 225.2(8), the judge shall determine the question summarily and may confirm, set aside or vary the authorization and make such other order as the judge considers appropriate. (12) Where any question arises as to the course to be followed in connection with anything done or being done under this section and there is no direction in this section with respect thereto, a judge may give such direction with regard thereto as, in the opinion of the judge, is appropriate. (13) No appeal lies from an order of a judge made pursuant to subsection 225.2(11).   ...

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