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FCTD

Larouche v. Canada (Attorney General), 2015 FC 232

Delays in processing the file [30]            The applicant criticizes the CRA for failing to give earlier consideration to the fact that 2753 acted as a nominee for him and held Cinépix’s shares in his name. ...
FCTD

Canada (Citizenship and Immigration) v. Demurova, 2015 FC 872

The officer prepared a File Preparation and Analysis Template [FPAT] and placed it on file for consideration by the Citizenship Judge. [6]                On December 29, 2014, the Respondent appeared before the Citizenship Judge. ...
FCTD

Gordon v. Canada (Attorney General), 2016 FC 643

No. 349. [37]            In this case, the Minister’s Delegate failed to give any consideration to Mr.  ...
SCC

Fraser Valley Milk Producers' Assoc. v. Minister of National Revenue, [1929] SCR 435

Now therefore this Agreement witnesseth: That in consideration of the outlays and expenses incurred and to be incurred by the Association in providing means for handling, manufacturing and marketing the milk and dairy products of the Producer as mentioned herein, the said parties have agreed to, and do hereby agree as follows:— 1. ...
SCC

Montreal Trust Co. v. Minister of National Revenue, [1956] SCR 702

It is unnecessary to consider all the implications of that decision, but, so far as the point under consideration is concerned, I agree so unreservedly with the [Page 706] reasoning of Luxmoore J. where he is dealing with comparable provisions of the Imperial Finance Act, 1894, that I transcribe the relevant paragraph which appears at pp. 807-8 of the report:— It is argued that the power in the present case is a limited power and does not authorize the donee to appoint or dispose of the property subject to it as he thinks fit. ...
SCC

Bathurst Paper Limited v. Minister of Municipal Affairs of New Brunswick, [1972] SCR 471

There is another consideration that is equally telling. Legislative changes may reasonably be viewed as purposive, unless there is internal or admissible external evidence to show that only [Page 478] language polishing was intended. ...
SCC

Minister of National Revenue v. F. David Malloch Memorial Foundation, [1971] SCR 141

Justice Gibson, I am unable to reach any other conclusion from a consideration of the combined effect of the two statutory provisions. ...
SCC

Minister of National Revenue v. MacLean Mining Company Limited, [1970] SCR 877

In my view, the decisive consideration in favour of the Minister’s decision is that the MacLean orebody was not developed as a separate mine. ...
SCC

Minister for Mines (Ontario) v. Rio Algom Mines Ltd., [1969] SCR 880

With respect, it is my view that there is no relationship between that matter and the matter now under consideration. ...
SCC

The Queen v. Westcoast Transmission Company Limited, [1962] SCR 125

The words "purchaser", "retail sale" and "purchase price" are defined in s. 2 of the Act as follows: "purchaser" means any person who acquires tangible personal property at a sale in the Province for his own consumption or use, or for the consumption or use by other persons at his expense, or on behalf of, or as the agent for, a principal who desires to acquire such property for consumption or use by such principle or other persons at his expense; "retail sale" means a sale to a purchaser for purposes of consumption or use and not for resale; "sale price" or "purchase price" means a price in money, and also the value of services rendered, the actual value of the thing exchanged, and other considerations accepted by the seller or person from whom the property passes as price or on account of the price of the thing covered by the contract, sale, or exchange, and includes the charges for installation of the thing sold, for interest, for finance, for service, for customs, for excise, and for transportation, whether or not such are shown separately on the invoice or in the vendors' books; The appellant's contention is that the concluding words of subs. (3) of s. 3, i.e., "the same tax in respect of the consumption or use of such property as would have been payable if the property had been purchased at a retail sale in the Province", mean that the respondent is required to pay, not a tax of five per centum of the actual purchase price of the property purchased, but five per centum of what would have been the retail price of the property purchased, assuming that the steel pipe had been purchased at a retail sale in British Columbia. ...

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