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FCTD

Canada (Minister of National Revenue) v. Industries Vogue Ltée, docket T-1270-92

However, because of the nature of the other materials used in constructing an above-ground pool and the way in which the latter is ordinarily assembled and installed, they considered that the contribution of the sheet to the load-bearing system or body of the pool generally used is insignificant. ...
FCTD

Wilson v. Canada, docket T-1677-79

There was no such contrary order in this case. [41]      In the present cases, no contrary orders were made with respect to interest on the costs awarded to the plaintiff. [42]      Section 40 of the Federal Court Act, as considered by the Court of Appeal in Bethlehem Copper, is identical to the section of the Federal Court Act which I have concluded was applicable to the 1988 judgments. ...
FCTD

Merlis Investments Ltd. v. Canada (Minister of National Revenue), docket T-1814-99

Such justification was considered by the Tax Court of Canada in Ginsberg, [1994] 2 C.T.C. 2063 at 2073, where it concludes:              I believe that if there is a delay that prima facie indicates a failure to examine and assess a return with all due dispatch as required under subsection 152(1) of the Act there is an onus on the respondent to establish by evidence pertaining to the manner in which that return was dealt with that the delay was not unreasonable....              ...
FCTD

Tower v. Canada (Minister of National Revenue), 2002 FCT 929

.), the Supreme Court considered the nature of the Requirement to Provide Information. ...
FCTD

Rjr-Macdonald Inc. v. Canada, docket T-1686-91

Justice Hugessen goes further to suggest that perhaps even the double taxation impact should not, in the current environment, be considered a significant factor. 7)      GENERAL PRINCIPLES OF INTERPRETATION OF TAX LEGISLATION [21]      In Friesen v. ...
FCTD

Lornex Mining Corporation Ltd. v. Canada, docket T-1330-84

For accounting purposes, commercial production was considered to commence on October 1, 1972.      ...
FCTD

HomeAway.com, Inc. v. Hrdlicka, 2012 FC 1467

I do not believe that the official mark could only be considered adopted and used if the tax forms were effectively issued ...
FCTD

Public Service Alliance of Canada v. Canada Revenue Agency, 2011 FC 207

Interest properly considered in adverse effect analysis [73]            CRA urges that the principal lump sum payments and the interest sums were inexorably linked as part of the remedy ordered by the Tribunal and further negotiated by the parties. ...
FCTD

Canada (Citizenship and Immigration) v. Tazaki, 2011 FC 1173

  [33] It can reasonably be inferred from these indicia that the Citizenship Judge considered the threshold residence test (Canada (Minister of Citizenship and Immigration) v Guettouche, 2011 FC 574 at para 15). ...
FCTD

Transport Ronado Inc. v. Canada, 2007 FC 166

  [45]            I agree with the defendant’s position, because in my opinion Canada Post can be considered to be an agent of the Minister of National Revenue only where it is expressly mentioned in the Act or regulations in force, as for example in the case of the mailing of income tax returns during the month of April of every year. ...

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