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EC decision

William Keppie Murray v. Minister of National Revenue, [1950] CTC 7, [1949-1950] DTC 723

Minister of National Revenue, [1948] S.C.R. 486, the question of the onus resting on an appellant from an assessment under the Income War Tax Act was under consideration. ... After giving full consideration to the evidence, I have reached the conclusion that the appellant herein has not satisfied the onus resting on him ‘‘to demolish the basic fact on which the taxation rested’’, namely, that the deductible expenses incurred in connection with his business operations, did not exceed $1,500. ...
EC decision

The Minister of National Revenue v. Mr. E., [1950] CTC 345

The contract further provided as follows: "THIS CONTRACT WITNESSETH FURTHER that in consideration of payments made in any other manner than in the manner above indicated, such an annuity shall be paid at the date fixed for the commencement of the annuity as the total payments made (increased at 4 per cent compounded yearly) will purchase at the rate in effect at the date of this contract.’’ ... In consideration of the total payment of $13,639.81 made under this contract, the purchase of an annuity of $1,200.00 guaranteed ten years has been completed.’’ ...
EC decision

‘Hunting Merritt Shingle Co. Ltd. v. Minister of National Revenue, [1951] CTC 132, [1951] DTC 466

On consideration, I find that contention unanswerable. There is ample legal authority to show that when a Court or other tribunal has to make computations that prima facie require it to forecast the future, it must do what it can with the available materials, and must often work with conventional rules and assumptions; but still if by the time of the computation the event, which ordinarily the tribunal would have to anticipate, has actually taken place, the tribunal must proceed on the actual facts, and can no longer act on artificial rules for measuring the future probabilities as its guide. ... However, different considerations apply to the $17,228.38 reserve allowed and set up before 1947. ...
EC decision

Minister of National Revenue v. Stanley Mutual Fire Insurance Company, [1951] CTC 265, [1951] DTC 529

That consideration appears to me to dispose of the present case. In my opinion, a member of the appellant company, when he pays a premium, makes a rate- able contribution to a common fund, in which he and his copartners are jointly interested, and which is divisible among them, at the times and under the conditions specified in their policies. ... As I see it, the very same conditions are taken into consideration in fixing premium rates as in the case of an ordinary fire insurance company. ...
FCTD

Guillemette v. Canada (attorney General), 2025 FC 250

Issues and Standard of Review [7] Preliminary issues raised by the Respondent involve the renaming of the Respondent and the consideration of the CERB and the CRB decisions in this application for judicial review. [8] The Respondent asserts, and I agree, that the proper Respondent in this matter is the Attorney General of Canada rather than the Minister of National Revenue. ... Two considerations regarding the statutory interpretation exercise are relevant: first, a Court conducting statutory interpretation does not conduct a de novo analysis but seeks to determine whether the interpretation by the decision maker is reasonable (Vavilov at para 116), and second, in the statutory interpretation exercise, the text is the interpretive “anchor” (Quebec (Commission des droits de la personne et des droits de la jeunesse) v Directrice de la protection de la jeunesse du CISSS A, 2024 SCC 43 at para 24). [23] This statutory interpretation argument was not placed before the decision maker and therefore no interpretation of the statute on this point appears in the reasons. ...
TCC

Dumais Et al v. M.N.R., 2007 TCC 261

For the same reasons as mentioned above, I did not take this testimony on this point and the conclusion into consideration. ... No. 464 (Q.L.), the appellants argue that the Court should not take into consideration the unpaid work performed by the employees outside of the relevant periods ... This conclusion is obvious, especially if I take into consideration the numerous hours of unpaid work performed by the employee during the low season ...
TCC

Villa Beliveau Inc. v. The Queen, 2004 TCC 701

Consideration was given to land use controls including the municipal zoning and official plan documents which affect the subject properties. This was followed by an analysis and consideration of the highest and best use concept and the various methods of appraisal. ... Based on this consideration the life lease tenure would appear to carry a financial cost of from 3% to 8%. ...
TCC

Campbell v. The Queen, 2004 TCC 460 (Informal Procedure)

A purposive and contextual analysis will assist in the consideration of this question ... As to legislative reform, I am hopeful that Parliament will revisit the impugned provisions to obviate the need for any further judicial consideration of them. ... In awarding such amount I have taken into consideration all the factual circumstances of the case as generally set out in these Reasons.     ...
TCC

Produits Forestiers Donohue Inc. v. The Queen, docket 98-2655-IT-G

DMI was incorporated in 1988 to build and operate a bleached chemithermomechanical pulp (BCTM pulp) mill in Matane's industrial park. [7]            The cost to build the pulp mill was approximately $240,000,000, of which some $145,000,000 was provided by a banking consortium, $70,000,000 in equal shares by Donohue and Rexfor in consideration of common shares and $25,000,000 [2] by Rexfor in consideration of Class A preferred shares. ... Nor had consideration been given at any time to closing the mill permanently. ... There was no evidence that that decision had been influenced by extraneous considerations. ...
FCA

Kreishan v. Canada (Citizenship and Immigration), 2019 FCA 223

It is important to note that the standard of review by which the Federal Court reviews RPD and RAD decisions does not preclude consideration of the merits or factual findings of either tribunal. ... Under consideration by the court was what was characterized as a deficient benefit compensation scheme for those injured in the course of military service. ... I have therefore given careful consideration to whether this case falls within the scope of the “special circumstances” left open by the Supreme Court in Gosselin, which would require an affirmative obligation on government. ...

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