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FCA

Canada v. Hirschfield, 2025 FCA 17

The unjust enrichment he pleads does so too, and in that connection he further pleads entitlement to restitution of “ill-gotten gains” equivalent to the difference between the amount of the disability pension benefits class members were owed and the amount paid out. [49] Rule 334.16(1) of the Federal Courts Rules sets out five conditions that must be met for a proceeding in the Federal Court to be certified as a class proceeding: (1) the pleadings disclose a reasonable cause of action; (2) there is an identifiable class of more than one person; (3) the claims raise common questions of fact and law; (4) a class proceeding is the preferable procedure for the just and efficient resolution of the common questions; and (5) there is an adequate representative plaintiff or applicant. [50] The motion judge found that all five conditions were met, and granted certification accordingly. ...
Scraped CRA Website

Costs that Fall within the Scope of Subsection 183(2)

Therefore, anything related to taking possession of property would be in connection with the seizure or repossession. ... It is the Department's view that the lawyers' services were acquired in connection with the seizure of the property. ... It is the Department's view that the appraiser's fees were acquired in connection with the seizure of the property. ...
TCC

Cameco Corporation v. The Queen, 2018 TCC 195, aff'd 2020 FCA 112

It had no connection to Canada. Why bring it here, subject that uranium to Canadian tax when it never was from Canada in the first place? ... Well, I said: “Please review the quantity and delivery date in connection with the BfE approval.” ... The losses result from the ps activity and the ps activity itself has no connection with the resource activity of the Appellant. ...
TCC

Ballantyne v. The Queen, 2009 DTC 1024, 2009 TCC 325

In this regard, the Tax Court judge found at page 15 of his decision that "there is no evidence that the fishing activity of the Company which gives rise to the incomes of the Appellants has any close connection with the Reserve, or any historic, social or cultural connection with either the Band or the Reserve". ...
TCC

722540 Ontario Inc. v. The Queen, 2002 DTC 1307 (TCC)

The Minister says that it is not because no Notice of Objection was filed under section 165 of the Act. 540 has also appealed from its assessments for 1990 and 1991, claiming to be entitled to carry a non-capital loss forward from 1988 and apply it to those years. [3]            The expenses disallowed by the Minister are interest on certain loans, and in the case of Novopharm's 1987 year, a financing fee of $500,000 and a consulting fee of $200,000, both paid in connection with one of those loans. facts [4]            The events giving rise to the appeals were a carefully orchestrated series of transactions designed to permit Novopharm to take advantage of the accumulated losses of $11,634,134 and the unused Canadian exploration and development expenses (CEDE) totalling $10,724,370 of a company called Royal Scot Resources Ltd. ... Fogler, Rubinoff, $75,549.84 for their services in connection with these transactions. ...
TCC

Nova Scotia Power Inc. v. The Queen, 2002 DTC 1432 (TCC)

Liquor Control Act, R.S.N.S. 1989, c. 260, s. 18                 18             All property, whether real or personal, all money acquired, administered, possessed or received by the Commission and all profits earned in the administration of this Act, shall be the property of Her Majesty in right of the Province, and all expenses, debts and liabilities incurred by the Commission in connection with the administration of this Act shall be paid by the Commission from the money received by the Commission under such administration. Nova Scotia Hospital Act, R.S.N.S. 1989, c. 313, s. 4                 4               The Hospital and all the real and personal property and assets of every kind held and enjoyed in respect to or in connection with the Hospital are vested in Her Majesty in right of the Province. ...
SCC

Stubart Investments Ltd. v. The Queen, 84 DTC 6305, [1984] CTC 294, [1984] 1 SCR 536

At the time of the 1966 sale to Grover, Grover wished to continue the use of the name of the appellant in connection with the business for a second reason. There were serious claims outstanding in the courts against Grover in an action brought in connection with its cement business, and the testimony in the record reveals that it was desirable "to make the transfer as inconspicuous as possible" in order not to encourage Grover's adversaries in continuing the [Page 552] litigation, "so long as it was legally binding". ...
FCTD

Dand Auto Parts Ltd. v. The Queen, 90 DTC 6533, [1990] 2 CTC 385 (FCTD)

Have you had any connection with horses? Only from a hobby point of view. ... From 1979 Milburn advised Dand and his companies in connection with the horse breeding business, although he only spent approximately five per cent of his time doing this. ...
TCC

TD Securities (USA) LLC v. The Queen, 2010 TCC 186

It is nonetheless a strong confirmation that the intended purpose and scope of Articles I and IV of the US Treaty were that the treaty apply to those bearing full tax liability in either of the contracting states based upon the nature and extent of their connections with that country ... It is important to note that the solutions developed in this report do not exclude the possibility that Member countries may in their bilateral relations develop different solutions to the problems of double taxation which may arise in connection with partnerships.   ...
QCQC decision

R. v. Landes, [1988] 1 CTC 124 (Queb. Ct. S.P.)

., says: Sums Payable on Termination of Business The question of when sums payable in connection with the termination of business arrangements are to be regarded as profits of a business and when as capital receipts has been considered in a number of English and Scottish cases which were referred to in the course of the argument and the principles applied in them appear from the following extracts. ... In this connection I note, and adopt, the dictum approved by Lord Evershed, in Wiseburgh v. ...

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