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Thus, he argues that the Applicant is relying on overly-general assertions of privilege, which are considered to be insufficient to ground a proper privilege. ... (Bryant, Evidence in Canada at para 15.44) [35]   According to the Respondent, the proper approach is to follow Wang v Canada (Public Safety and Emergency Preparedness), 2016 FC 493 [Wang], in which Justice Mactavish listed the following factors to be considered in the balancing exercise: 1.   ... The procedure and outcome of such an exercise must always be considered in the context of the litigation at hand. [45]   Thus, having dealt with the question of class privilege, let us now address the essential components of a section 37 application so that the Judicial Review Applications can eventually come to fruition. ...

Gadwa, for his part, appealed Justice Strickland’s finding that he engaged in corrupt elections practices. [12]   In June 2016, the Kehewin Council considered a complaint of malfeasance and neglect of duty or misconduct against Mr. ... However, the Court also considered there was no justification for the noncompliance and there was a need for deterrence, among other factors. ... I have also considered and find them to be reasonable. This amount insures that, to the extent possible, the Applicants are not out of pocket for what they have done to ensure the proper enforcement of the November 10, 2017 Order. [60]   There is no need to assess the amount owing, given my assessment of its reasonableness. ...

To do so, I must look to the words of the statutes, and interpret them with regard to their object, text, the context of the provisions considered together, in addition to potential issues of absurdity, redundancy, or unfairness (Medovarski v Canada (Minister of Citizenship and Immigration); Esteban v Canada (Minister of Citizenship and Immigration), [2005] 2 S.C.R. 539 at para 8).   ... It is not necessary to reproduce these provisions in full, though I would note the following particular passages, with my emphasis: 10. […] (6) A sponsorship application that is not made in accordance with subsection (1) is considered not to be an application filed in the prescribed manner for the purposes of subsection 63(1) of the Act. […] 12. ... In other words, the “prescribed manner” requirement more clearly set forth in subsection 10(6) of the IRPR is a condition to be considered an applicant under subsection 63(1) of the IRPA, rather than an individual requirement to enjoy a right of appeal under the IRPA, just as being a member of the classes of persons set forth in subsection 63(2) to 63(5) of the IRPA is also insufficient to enjoy a right of appeal. [48]   With this in mind, an appeal to the IAD is subject to a condition precedent, that is, a negative decision rendered by the relevant decision-maker (a visa officer), as is the case for each of subsections 63(1) through 63(5) of the IRPA. [49]   In principle, a right of appeal cannot be said to accrue, arise, vest, or “crystallize” before the decision subject to an appeal has been made.   ...

For the purposes of the Act, a child is considered to be maintained by an applicant in a month if 9. ... She stresses the fact that for a child to be considered to be maintained by an agency, the child must be “dependent on the agency for his or her care... to a greater extent than on any other department, agency or institution or on any person.” ... In this perspective, a child who is the subject of a youth protection measure may be considered as being maintained by his or her parents, where he or she stays with them for more than half of a given month. ...

West Coast would process its own film during that time and would hence be considered a manufacturer. ... However, should West Coast Photo develop film provided to them by their customers, they would be considered to be a manufacturer or producer under Section 26(7) of the Act (copy enclosed). ... Counsel further submits that the evidence indicates that the total of the price charged was divided up by the percentages and that the total price charged should be considered the price charged for the work done. ...

Barrett would not be considered a solicitor of record until he had filed a Notice of appointment as Mr. ... The December 2019 Letter states that when the financing was initially considered, Mr. ... F-7), taxpayers may seek judicial review of administrative discretionary decisions. [64] The Federal Court has considered applications for judicial review of decisions made by CRA Collections refusing to lift liens. ...

Moreover, since part of another lot was involved and there are no means of determining whether the price of 55c a foot asked was affected in any way by part of Lot 99 being included in the option with Lot 101, I would not consider that these documents, even if they had been proved and if the Minister had relied on them in establishing the assessment, could be considered as indicating the real market value of Lot 101 at the date of the deceased’s death. ... This would affect the rate of duty, even if plaintiff’s contention were adopted that Dame Dagenais should be considered as a usufructuary only and the valuation of her life interest be calculated on an actuarial basis in the manner provided in the Regulations. ... On the other hand, the estate was apparently assessed on the basis that the entire assets should be considered as having passed to the widow Dame Dagenais, which conclusion I have rejected. ...

</p>] MacGuigan J.A. concluded: Indeed, even apart from authority, it should be obvious that words can never be considered apart from their context, since context imparts meaning to that which it surrounds. ... He stated: Secondly, for the purpose of the deduction provided for in paragraph 20(1)c) of the Act, it has also been established in [Bronfman Trust] that what should be considered is not the purpose of the borrowing itself but rather the purpose for which the borrowed money was used. ... C.A.), this Court outlined three factors to be considered in determining whether the income of a taxpayer has been unduly or artificially reduced contrary to subsection 245(1). ...

The jurisprudence also confirms that the Court has the jurisdiction to strike a notice of appeal. [53] In Lessard-Gauvin v Canada (Attorney General), 2019 FCA 233, the Federal Court of Appeal considered a motion to strike out a notice of appeal and agreed that the Court had such inherent authority. ... The Respondent argues that, for each error alleged in the notice of appeal, the Appellant’s position is unfounded and/or vague, and it is plain and obvious that the appeal cannot succeed. [10] In reply, the Appellant insists that the threshold for striking out the notice of appeal is very high. [54] In Tuccaro v Canada, 2014 FCA 184, the Federal Court of Appeal considered the appeal of an Order of the Tax Court that struck parts of the notice of appeal. ... As noted in Imperial Tobacco at para 25, the “context of the law and litigation” must be considered. ...

., to be included in income,-- any amount (other than an amount referred to in paragraph 18(1)(m), paid or payable by the taxpayer, or a prescribed amount) that became receivable in the year by virtue of an obligation imposed by statute or a contractual obligation substituted for an obligation imposed by statute by (i) her Majesty in right of Canada or a province, (ii) an agent of Her Majesty in right of Canada or a province, or (iii) a corporation, commission or association that is controlled, directly or indirectly in any manner whatever, by Her Majesty in right of Canada or a province or by an agent of Her Majesty in right of Canada or a province As a royalty, tax (other than a tax or portion thereof that may reasonably be considered to be a municipal or school tax), lease rental or bonus or as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property or a property that would have been a Canadian resource property if it had been acquired after 1971, or (v) the production in Canada of (A) petroleum, natural gas or related hydrocarbons from a mineral resource or an oil or gas well, or (B) metal or minerals, to any stage that is not beyond the prime metal stage or its equivalent, from a mineral resource Situated on property in Canada in which the taxpayer had an interest with respect to which the obligation imposed by statute or the contractual obligation, as the case may be, applied;   Inducement, reimbursement, etc. (x) any particular amount (other than a prescribed amount) received by the taxpayer in the year, in the course of earning income from a business or property, from (i) a person or partnership (in this paragraph referred to as the “payer”) who pays the particular amount (A) in the course of earning income from a business or property, (B) in order to achieve a benefit or advantage for the payer or for persons with whom the payer does not deal at arm’s length, or (C) in circumstances where it is reasonable to conclude that the payer would not have paid the amount but for the receipt by the payer of amounts from a payer, government, municipality or public authority described in this subparagraph or in subparagraph (ii), or (ii) a government, municipality or other public authority, where the particular amount can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a refund, reimbursement, contribution or allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of (A) an amount included in, or deducted as, the cost of property, or (B) an outlay or expense, to the extent that the particular amount (v) was not otherwise included in computing the taxpayer’s income, or deducted in computing, for the purposes of this Act, any balance of undeducted outlays, expenses or other amounts, for the year or a preceding taxation year, (vi) except as provided by subsection 127(11.1), 127(11.5) or 127(11.6), does not reduce, for the purpose of an assessment made or that may be made under this Act, the cost or capital cost of the property or the amount of the outlay or expense, as the case may be, (vii) does not reduce, under subsection 12(2.2) or 13(7.4) or paragraph 53(2)(s), the cost or capital cost of the property or the amount of the outlay or expense, as the case may be, and (viii) may not reasonably be considered to be a payment made in respect of the acquisition by the payer or the public authority of an interest in the taxpayer or the taxpayer’s business or property;     General limitations   18. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of   […]   (m) Royalties, etc. – any amount (other than a prescribed amount) paid or payable by virtue of an obligation imposed by statute or a contractual obligation substituted for an obligation imposed by statute to (i) Her Majesty in right of Canada or a province, (ii) an agent of Her Majesty in right of Canada or a province, or (iii) a corporation, commission or association that is controlled, directly or indirectly in any manner whatever, by Her Majesty in right of Canada or a province or by an agent of Her Majesty in right of Canada or a province As a royalty, tax (other than a tax or portion thereof that may reasonably be considered to be a municipal or school tax), lease rental or bonus of as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property or a property that would have been a Canadian resource property if it had been acquired after 1971, or (v) the production in Canada of (A) petroleum, natural gas or related hydrocarbons from a mineral resource in Canada or an oil or gas well in Canada, or (B) metal or minerals, to any stage that is not beyond the prime metal stage or its equivalent, from a mineral resource in Canada. ...