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FCTD

Colin McPhail v. Her Majesty the Queen in Right of Canada as Represented by the Minister of National Revenue, [1994] 1 CTC 259, 94 DTC 6198

That judgment in the reasons therefore did, however, have something relevant to say in the present circumstances, at page 532 (D.T.C. 6653), beginning with consideration of provisions of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
FCTD

Hughes v. Canada (Human Rights Commission), 2021 FC 728

Making such serious allegations and failing to substantiate them is a factor to be taken into consideration in costs: see Stubicar v Canada (Deputy Prime Minister), 2013 FCA 203 [Gauthier JA]. ...
FCTD

Mohawk Oil Co. Ltd. v. Her Majesty the Queen, [1990] 2 CTC 173, 90 DTC 6434

Notwithstanding any other terms of this letter, the obligations of Buyer under Paragraph 7 "Secrecy" of the Purchase Agreement shall remain in full force and effect. (6) In consideration of the foregoing and except as herein otherwise provided, Buyer and Seller hereby release one another and all of their respective officers, directors, and employees, from liability for all claims of any nature whatsoever whether, contract or tort, arising out of or related in any way to the Purchase Agreement, the Option Agreement, or the negotiations leading up to the execution of either of the above Agreements or this Agreement. ...
FCTD

Frank Pavlakovich v. Her Majesty the Queen, [1989] 2 CTC 260

That reasonable expectation of income exacts some consideration of the specific revenues and expenses of the enterprise — albeit a family farm — even although the test is decidedly not a pure quantum measurement. ...
FCTD

Glen Williams v. The Queen, [1989] 1 CTC 117, [1989] DTC 5032

However, I do think that the place where the benefits are paid to the plaintiff should be a consideration when assessing situs of the benefits, based on Dickson, J.'s comment in Nowegijick at 22 (D.T.C. 5043) and D J. ...
FCTD

Her Majesty the Queen v. Gicleurs Astra Ltée, [1987] 1 CTC 161

Bearing in mind the scheme and spirit of the Customs Act, taking into consideration its subsection 2(3), which recommends that its wording be given the interpretation that will best ensure the protection of the revenue, and also taking into account its sections 247 and 248 set out above, it does not appear that, in view of the persuasive evidence presented by the plaintiff, the defendant here has credibly established both its good faith and unobjectionable conduct, at least conduct free of obvious negligence. ...
FCTD

Gurd’s Products Company Limited v. Her Majesty the Queen, [1981] CTC 195, 81 DTC 5153

It is uncontested that, during the years under appeal, Products engaged in no business whatsoever in Canada and the question under section 253 narrows down to a consideration of its activities between April 26, 1965 and the year 1973. ...
FCTD

Henry Cival v. Her Majesty the Queen, [1981] CTC 392, 81 DTC 5311

Finally the jurisprudence that has developed on the kind of issue we are dealing with requires consideration. ...
FCTD

Lornex Mining Corporation Ltd. v. Her Majesty the Queen, [1996] 3 CTC 309, 96 DTC 6550

In this way, one must take into consideration the effect of section 28 of the Rules on every subsection in the Act which affects the exempt income of mines. ...
FCTD

Bacon St-Onge v. Conseil des Innus de Pessamit, 2021 FC 1093

Common Considerations [30] The starting point for the analysis is the inherent seriousness of contempt. ...

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