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FCTD

Thomas v. Canada (Public Safety and Emergency Preparedness), 2020 FC 290

Among other things, the Applicant has not demonstrated that he has taken steps to protect any of this information from disclosure in Australia – for example by shielding his connection to his business, or having an unlisted telephone number. ...
FCTD

KIK Custom Products Inc v. Canada (Border Services Agency), 2020 FC 462

Importantly, the officer was responding to inquiries and further representations from the applicant’s representatives in connection with the original request for a ruling.   ...
FCA

Canada (Attorney General) v. Impex Solutions Inc., 2020 FCA 171

Do the facts of the case constitute a "line of railway" and a "connection" for the purposes of triggering the carrier's interswitching obligations? ...
TCC

Swift v. The Queen, 2020 TCC 115

The six phrases that he used to identify those factors are listed below (without the elaborating comments provided by Justice Rouleau in respect of each factor): a) the nature of the property sold; b) the length of period of ownership; c) the frequency or number of other similar transactions by the taxpayer; d) work expended on or in connection with the property realized; e) the circumstances that were responsible for the sale of the property; and f) motive or intention. [13] [34]   Justice Rouleau then stated the following about motive or intention, which is the last item in the above list: 15.   ...
TCC

DiCaita v. The Queen, 2021 TCC 5 (Informal Procedure)

He does not offer an explanation for the balance. [63] The Respondent submits that the Appellant has not demonstrated how those expenses were incurred in connection with gaining an income from his rental properties. ...
FCTD

74712 Alberta Ltd. (Formerly Cal-Gas & Equipment Ltd. v. Her Majesty the Queen), [1994] 2 CTC 191, 94 DTC 6392

We don't like two companies with the same connection dealing at different branches under different managers. ...
FCTD

495187 Ontario Limited v. Her Majesty the Queen, [1994] 2 CTC 398, 94 DTC 6593

Even still subsection 232(10) further confirms the existence of the judiciary's discretion in regard to these seizure sections: 232(10) Where any question arises as to the course to be followed in connection with anything done or being done under this section, other than subsection (2), (3) or (3.1), and there is no direction in this section with respect thereto, a judge may give such direction with regard thereto as, in his opinion, is most likely to carry out the object of this section of allowing solicitor-client privilege for proper purposes. ...
TCC

Donald Thomson, Anne Taylor and John W. White v. Minister of National Revenue, [1994] 2 CTC 2136, 93 DTC 320

White stated that after October 10, 1984, the publicity surrounding SRTC flips and the new government policy to prohibit such transactions in the future, made it virtually impossible to raise money if investors saw any project as having a connection with the SRTC program. ...
FCTD

Special Risk Holdings Inc. v. Her Majesty the Queen and Minister of National Revenue, [1994] 1 CTC 274, 94 DTC 6151

I do not follow the letter and will have to talk to Verchere on the telephone in connection with it. ...
TCC

Bronson Homes Limited v. Minister of National Revenue, [1993] 2 CTC 2060

She says further that if you really look at the facts, because of the close connection between all the parties in these different companies, that if there was any oral agreement, it was between the two shareholders personally and Bronson. ...

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