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TCC

Jaggi c. M.R.N., 2005 TCC 166

This would simply mean that I have found that the new factors not considered were not relevant. ... Wrights' Canadian Ropes Ltd., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the court may not interfere. ...
TCC

Lelievre and Falardeau v. M.N.R., 2003 TCC 55

  [36]     The whole of the evidence, the remuneration, the terms and conditions and the duration of the employment must be considered. ... Cases considered   Théberge v. Canada (Minister of National Revenue ‑ M.N.R.), [2002] F.C.J. ...
TCC

Matériaux Économiques Inc. v. M.N.R., 2003 TCC 449

In determining his remuneration, Daniel St‑Pierre considered the profits generated by the treatment division. ... Deputy Judge Somers     Cases considered   Bayside Drive‑In Ltd. v. Canada (Minister of National Revenue ‑ M.N.R.), [1997] F.C.J. ...
FCTD

Hewage v. Canada (Prime Minister) and Canada (Attorney General), 2024 FC 901

See Annex “B” for applicable legislative provisions. [4] The present motion raises the sole issue of whether the Court should strike the Notice of Application in its entirety, without leave to amend. [5] Having read the parties’ motion materials carefully and considered the applicable jurisprudence, I find that the Application has no prospect of success because it raises no cognizable or justiciable administrative law claim. ... FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1263-23   STYLE OF CAUSE: NEVILLE HEWAGE v CANADA (PRIME MINISTER) AND THE ATTORNEY GENERAL OF CANADA   MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES   ORDER AND REASONS: FUHRER J.   ...
FCTD

Ge v. Canada (National Revenue), 2025 FC 1205

While some leniency for drafting errors may be afforded to a self-represented litigant, they remain responsible to inform and educate themselves and to comply with the Rules (Gaskin v Canada, 2024 CanLII 28268 at para 15; Turmel v Canada, 2021 FC 1095 at para 25; Theriault v Canada (Attorney General), 2022 FC 722 at para 17; Koehne v Canada (Citizenship and Immigration), 2016 FC 1083 at para 14). [32] Associate Judge Horne correctly considered the Hennelly factors and determined that the Applicant’s motion to extend the time to file proposed submissions in response to the status review must be dismissed because there was no merit in the proposed submissions. ... DATED: july 8, 2025 MOTION IN WRITING CONSIDERED IN OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES WRITTEN SUBMISSIONS BY: Rui Ge For The Applicant (SELF-REPRESENTED) Laurent Bartleman Lucy Yao For The Respondents SOLICITORS OF RECORD: Attorney General of Canada Toronto, Ontario For The Respondents   ...
SCC

65302 British Columbia Ltd. v. Canada, 99 DTC 5799, [1999] 3 SCR 804

Absent an express  indication to the contrary, the presumption that Parliament would not intend to encourage the violation of other laws must be considered.  ... Royal Insurance Co., [1938] 2 All E.R. 602; considered:   TNT Canada Inc. v. ... If so, would this policy extend to situations where the fine was levied for actions not considered illegal in Australia or considered to be contrary to our public policy?   ...
TCC

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251

The GAAR will not apply to deny a tax benefit where it may reasonably be considered that the transactions were carried out in a manner consistent with the object, spirit or purpose of the provisions of the Act, as interpreted textually, contextually and purposively.   ...   [96]          In this respect the transactions in this case differ from those considered by this Court and the Federal Court of Appeal in Copthorne Holdings Ltd v. ...   [105]      While not specifically argued, one might wonder if the specific dividend stripping rule in section 212.1 was avoided in this case and whether that avoidance could be considered to be abusive. ...
TCC

AE Hospitality Ltd. v. M.N.R., 2019 TCC 116

Alternatively, the 2016 decisions considered whether AE was a placement agency pursuant to the provisions of the EIR and the CPPR. ... In 1392644 Ontario Inc. o/a Connor Homes v Minister of National Revenue, [7] Justice Mainville of the Federal Court of Appeal reviewed the cases in which the intentions of the parties were considered. ... As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered "in the light of" the parties' intent. ...
SCC

Canada (Attorney General) v. Collins Family Trust, 2022 SCC 26

Holt, [2013] UKSC 26, [2013] 2 A.C. 108; considered: Shell Canada Ltd. v. ... Canada (Attorney General), 2016 SCC 55, [2016] 2 S.C.R. 670, the chambers judge considered himself bound by it. ... The scheme complied with the ITA   because the shares were substituted property for the gifted property, but the Minister considered the result abusive. ...
TCC

Québecor Inc. v. The King, 2023 TCC 142

Next, the Court must determine whether each transaction in the series may reasonably be considered to have been undertaken primarily for a bona fide purpose. ... However, the entire series of transactions should be considered in order to determine whether the individual transactions within the series abuse one or more provisions of the Act. ... To the extent a shareholder receives an amount less than or equal to the PUC it will be considered a non-taxable return of capital. ...

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