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SCC

Canada (Attorney General) v. Federation of Law Societies of Canada, 2015 SCC 7, [2015] 1 SCR 401

On Liberty and Considerations on Representative Government, by R. B. McCallum, ed. ... Different considerations would come into play in relation to regulatory audits of lawyers conducted on behalf of lawyers’ professional governing bodies. ... Mill, On Liberty and Considerations on Representative Government (1946), at p. 8.  ...
SCC

Piekut v. Canada (National Revenue), 2025 SCC 13

A statutory provision is not “ambiguous” in the required sense simply because different courts or authors have reached different conclusions as to its proper interpretation (Bell ExpressVu, at para. 30). [49]                          In sum, as Professor Sullivan explains, the prime directive in statutory interpretation is that after taking into account all relevant and admissible considerations. . . the court must adopt an interpretation that is appropriate. ... As noted in the Standing Senate Committee Report (2003), “former students may be insolvent only temporarily, and do have the ability to repay their loans because they will have higher-than-average income in the future” (p. 51). [93]                          Borrowers have a special obligation to repay student loans partly because such loans are publicly funded and are extended to borrowers based on financial need rather than ordinary commercial lending considerations. ... As Sullivan explains, when conducting statutory interpretation: At the end of the day, after taking into account all relevant and admissible considerations, the court must adopt an interpretation that is appropriate. ...
SCC

Angle v. M.N.R., 74 DTC 6278, [1975] 2 S.C.R. 248

[Page 267] The basis of issue estoppel as well as a cause of action estoppel has been variously explained; for example, that it is “founded on considerations of justice and good sense” (see New Brunswick Railway Co. v. ...
SCC

Bronfman Trust v. The Queen, [1987] 1 S.C.R. 32, 87 DTC 5059, [1987] 1 CTC 117

In the present case the borrowed money was originally used to make capital allocations to the beneficiary for which the Trust received no property or consideration of any kind. ...
SCC

First Vancouver Finance v. M.R.N., 2002 DTC 6998, 2002 SCC 49, [2002] 2 SCR 720

It is in effect a sale by a company of its accounts receivable at a discounted value to the factoring company for immediate consideration.”    16                                Wimmer J. observed that, according to  Alberta (Treasury Branches), an absolute and unconditional assignment of book debts is beyond the reach of the Minister under garnishment provisions.  ...
SCC

The Queen v. Savage, 83 DTC 5409, [1983] CTC 393, [1983] 2 SCR 428

Distinguishing this case from Phaneuf, there was no element of gift, personal bounty or of considerations extraneous to Mrs. ...
SCC

Backman v. Canada, 2001 DTC 5149, 2001 SCC 10, [2001] 1 SCR 367

The question at this stage is whether the taxpayer can establish an intention to make a profit, whether or not he was motivated by tax considerations.  ...
SCC

In re The Bankruptcy of General Fireproofing Co. of Canada Ltd., [1937] SCR 150

As to the landlord’s claim, different considerations arise. His claim rests upon his right of distress and his cognate “preferential lien”; but it becomes operative solely by force of s. 126. ...
SCC

In Re Henderson, [1930] SCR 45

There is authority in this court for the proposition that, on the return of a writ of habeas corpus, the only consideration which can be entered upon by a judge of the Supreme Court of Canada is the sufficiency of the commitment. ...
SCC

The Queen v. Premier Mouton Products Inc., [1961] SCR 361

The right of respondent to be reimbursed these moneys, which it paid to appellant, involves the consideration of two questions:—(i) Whether, under the general law, there is, in like circumstances, a right to recover moneys paid, and, in the affirmative, (ii) Whether this right to recover, under the general law, is barred, in the present instance, by any of the statutory provisions of the Excise Tax Act. ...

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