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FCTD

Mustang Engineering and Construction Ltd. v. Canada, docket T-2772-93

I note no other factual details underlying that decision are reported, and with no basis for understanding the decision, I do not find it helpful. [16]      Finally, Mustang relies upon Revenue Canada Ruling 9110.050/93 dated February 10, 1984, in which quarry and gravel production operators were held to be manufacturers or producers who were entitled to the federal tax exemption for equipment under Part XIII of Schedule III of the Act. [17]      In my opinion, the wording of the paragraph 1(e) is plain: the activities must occur exclusively at a mine or quarry, not simply in connection with mining or quarrying operations. ...
FCTD

Ebco Industries Ltd. v. Canada, docket T-2519-90

Individual words have definitions which can be looked up in dictionaries, but they acquire the power to communicate a meaning primarily through their connection with other words as part of a structure of meaning. ...
FCTD

Capital Vision Inc. v. Canada (Minister of National Revenue), docket T-493-00

The applicants submit that this suggests that the requests are made in connection with the Capital Vision Inc. audit and note that there is no other audit in evidence. [62]            In Montreal Aluminium Processing Limited et al. v. ...
FCTD

Pacific Network Services Ltd. v. Canada (Minister of National Revenue), 2002 FCT 1158

The Court found that section 231.2 of the Act, when read in conjunction with Article XXVII of the Canada-United States Tax Convention (1980) and section 3 of the Canada-United States Tax Convention Act, S.C. 1984, c. 20 (which is very similar to section 2 of the Canada-France Income Tax Convention Act, 1976), give the Minister the power to issue a requirement for information sought by U.S. authorities in connection with their own taxation matters. [21]            Joyal J., (as he then was) who rendered the Court's decision, gave the following reasons at pages 181-82: Subsection 231.2(1) authorizes the Minister to serve a Requirement on any person for information or production of documents "for any purpose relating to the administration or enforcement of this Act". ...
FCTD

Markevich v. R., docket T-250-98

For the reasons given in connection with requirements to pay issued in respect of moneys owing under the federal Income Tax Act, in my opinion the exercise of a power to issue a requirement to pay is not a "proceeding in respect of a cause of action". [68]      However, the fact that section 32 does not apply to the issuance of a requirement to pay under the British Columbia Income Tax Act still leaves the question whether the British Columbia Limitation Act applies of its own force, and not by virtue of the reference to the applicable provincial law in section 32 of the Crown Liability and Proceedings Act. [69]      The first issue here is whether that provincial Limitation Act is capable of applying to a measure taken by the respondent, a Minister of the federal Crown, in an attempt to collect a debt owing to the provincial Crown under the British Columbia Income Tax Act. [70]      The British Columbia Interpretation Act R.S.B.C., c. 238 reverses the common law presumption that statutes do not bind the Crown in the absence of express words or necessary implication. ...
FCTD

Ticketnet Corp. v. Canada, docket T-2185-88

The first part was a contract for the supply of services by Air Canada in connection with the development of software for Ticketnet for a fee of $2 million. ...
FCTD

Young v. Canada, docket T-806-97

Wong said that the Fairness Committee did not want any connection between the Fairness Committee decision and the settlement of the Notice of Objection. ...
FCTD

Vancouver Trade Mart Inc. (Trustee of) v. Canada (Attorney General), docket T-1071-96

At 5283, he put it as follows:              Applying these principles, as I understand them, to materials prepared by accountants, in a general way, it seems to me                               (a) that no communication, statement or other material made or prepared by an accountant as such for a business man falls within the privilege unless it was prepared by the accountant as a result of a request by the business man"s lawyer to be used in connection with litigation, existing or apprehended; and                               (b) that, where an accountant is used as a representative, or one of a group of representatives, for the purpose of placing a factual situation or a problem before a lawyer to obtain legal advice or legal assistance, the fact that he is an accountant, or that he uses his knowledge and skill as an accountant in carrying out such task, does not make the communications that he makes, or participates in making, as such a representative, any the less communications from the principal, who is the client, to the lawyer; and similarly, communications received by such a representative from a lawyer whose advice has been so sought are none the less communications from the lawyer to the client.                       ...
FCTD

Ghali v. Canada (Transport), docket T-1153-96

In the first place, Dorval airport, as ADM states, will become a North American entry point for connections between the continent and Europe. ...
FCTD

Kruger Products Limited v. Canada, 2010 FC 381

., on behalf of the plaintiff, wrote a letter to Revenue Canada in which she inquired as to the status of Scott Paper’s refund claims “which were … filed … in connection with the payment of Federal Sales Tax on sales of facial tissues ” [my emphasis]. ...

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