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SCC

Iris Technologies Inc. v. Canada, 2024 SCC 24

T-2, and s. 18.5 of the FCA). [22]                           Rennie J.A. considered the true essence of Iris’ application for judicial review. ...
QCQC decision

Recorder’s Court, Et Al. v. Canadian Broadcasting Corporation, [1940-41] CTC 166

Après avoir fait la revue de toute la jurisprudence sur cette matière, cet auteur conclut comme suit (p. 25): It seems to follow from the cases already considered that the rule is as stated at the commencement of this chapter, and that an authority or corporation must be regarded as outside the exemption of the Crown unless it can substantiate a claim to exemption by Statute, or on the ground that it is by its origin or history closely associated with the Crown, so that it may be regarded as having emanated from the Crown in a similar manner to the great Departments of State; or apparently, unless it were created for the purpose of dealing with or controlling Crown property, or for the purpose of discharging duties previously performed by another exempted Department, as was the case with the Local Government Board. ...
TCC

Rio Tinto Alcan Inc. v. The Queen, 2017 TCC 67

Karda also argued that a reassessment that disallowed all the deductions that he had claimed could not be considered valid, if the sole purpose of the reassessment was to meet the limitation period. ... Consequential assessment (4.3) Notwithstanding subsections (4), (4.1) and (5), if the result of an assessment or a decision on an appeal is to change a particular balance of a taxpayer for a particular taxation year, the Minister may, or if the taxpayer so requests in writing, shall, before the later of the expiration of the normal reassessment period in respect of a subsequent taxation year and the end of the day that is one year after the day on which all rights of objection and appeal expire or are determined in respect of the particular year, reassess the tax, interest or penalties payable by the taxpayer, redetermine an amount deemed to have been paid or to have been an overpayment by the taxpayer or modify the amount of a refund or other amount payable to the taxpayer, under this Part in respect of the subsequent taxation year, but only to the extent that the reassessment, redetermination or modification can reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular year. ...
TCC

Godin v. M.N.R., 2016 TCC 88

Hours of Insurable Employment — Methods of Determination 9.1  Where a person's earnings are paid on an hourly basis, the person is considered to have worked in insurable employment for the number of hours that the person actually worked and for which the person was remunerated. 10(3)  Where the number of hours agreed to by the employer and the worker or group of workers under subsection (2) is not reasonable or no agreement can be reached, each worker is deemed to have worked the number of hours in insurable employment established by the Minister of National Revenue, based on an examination of the terms and conditions of the employment and a comparison with the number of hours normally worked by workers performing similar tasks or functions in similar occupations and industries. ...

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