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Therefore, in awarding costs under Rule 147(1), any settlement offer is simply one of the factors to be considered. ...

While publications of this type, including Explanatory Notes, are considered as permissible extrinsic aids... ...

. … [T]here is no doubt that the law practice of the appellant, when the relevant circumstances are considered in their entirety, certainly qualifies as having a personal aspect. ...

In the Federal Court judgment, Roussel J noted (at para. 5): He argued that since the shares acquired were subject to numerous blackout periods and he was considered an insider of ZCL for the purposes of the TSX and relevant shares legislation and regulations, the assessed value of the shares should not be more than 60% of the trading price on the date of purchase. ...

Boivin JA stated (at para. 7): [These] remarks … were ill-considered. ...

In confirming that CRA had not acted unreasonably in declining to recommend a remission order under s. 23(2) of the Financial Administration Act, Locke JA noted that CRA had “implicitly acknowledged the general intent noted in Montecristo … that GST/HST should be limited to consumption within Canada,” but had reasonably considered that “Goods purchased by non-resident consumers are only intended to be zero-rated if they are shipped to a destination outside Canada, or they are sent by mail or courier to an address outside Canada,” and further stated (at para. 23): The Assistant Commissioner concluded reasonably that the predicament in which Escape Trailer found itself … was caused not by any unintended results of the legislation, but rather by its failure to comply with any of the detailed conditions for zero-rating. ...

., on other Foundations) before her in her decision The appellant Foundation appealed from the refusal of the Minister to register it as a Canadian amateur athletic association on the grounds inter alia that the Minister had considered “irrelevant information in comparing the [Foundation] to other applicants and existing registered CAAAs” (para. 1). ...

The Tax Court had found that these certificates were “worthless pieces of paper” and that (contrary to the taxpayers’ pleadings) they had never acquired ownership of the pharmaceuticals and, therefore, could not be considered to have donated them. ...

Iris considered that the requirement in ETA s. 229(1) that net refund claims be paid “with all due dispatch” meant that it should be paid right away rather than awaiting the conclusion of the audit, and appealed the dismissal of its motion in the Federal Court, for an interim mandatory injunction to compel the payment of $62.3 million in GST/HST refunds, to the Court of Appeal. ...

. … … When the true character of the relief sought in this case is considered, the request for payment of the refund is an attempt to short-circuit the recourse mechanisms established by Parliament. ...