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FCTD

Célestin v. Canada (Public Safety and Emergency Preparedness), 2021 FC 223

Having considered the submissions of the parties, the Court fixes costs at $2,000.   ...
FCTD

Hervé Pomerleau Inc. v. R., [1996] 2 CTC 251

Accordingly, this notice must be considered nonexistent and the “fiscal change” referred to in clause 22.4 of the general Conditions is not deemed to have occurred prior to the date at which the bids were presented. ...
FCTD

Sturdy Truck Body (1972) Limited v. Her Majesty the Queen, [1995] 2 CTC 338

On February 12, 1987 the plaintiff was advised by way of a letter from the Ministry of a change in policy: In order for a truck body to be considered as being designed for and capable of permanent installation on a truck chassis with a gross vehicle mass rating of 7250 kg (16,000 lbs) or more, headquarters has indicated that the manufacturer must demonstrate that a sizeable percentage of that model of truck body is in fact installed on truck chassis over 16,000 lbs GVWR. ...
FCTD

Rodrique Blouin, Roland Dubeau, Emile Larochelle and James Racine v. Her Majesty the Queen, [1995] 2 CTC 412, [1995] DTC 5536

The question is of considerable importance for a person who, in good faith, acquires a property on the faith of such a certificate, and that is the perspective from which the effect of the certificates must be considered as the Minister is not questioning the bona fides of the plaintiffs. ...
FCTD

Nigel E. Brown v. Her Majesty the Queen, [1995] 1 CTC 208, 95 DTC 5126

Although he considered commercial applications for his theories, he was not successful in these ventures, nor did he patent the device. ...
FCTD

Faema Distributeur Inc. v. Minister of National Revenue, [1993] 2 CTC 56

Thus the provisions of Schedule III which contain these exemptions are independent, and although it may be useful to compare them, they must ultimately be considered and applied separately. ...
FCTD

E. Gordon Mackenzie v. Her Majesty the Queen, [1993] 2 CTC 92

He lists the following criteria which should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
FCTD

Pan Ocean Oil Limited v. Her Majesty the Queen, [1993] 2 CTC 236, 93 DTC 5330

.); aff'd [1966] S.C.R. 641, 56 W.W.R. 768, the Court considered the effect of an amalgamation under section 96 of the Corporations Act, 1953 (Ontario), $.O. 1953, c. 19. ...
FCTD

GSW Appliances Limited v. Her Majesty the Queen, [1993] 2 CTC 325

Accordingly, this evidence will not be considered by me. By notice of reassessment no. 623042, dated May 10, 1982, in respect of the plaintiffs 1976 taxation year, the said deduction from income in the amount of $652,754 claimed by the plaintiff under section 111 of the Act in its amended income tax return for its 1976 taxation year in respect of the non-capital loss claimed by the plaintiff in its 1977 taxation year, was not applied by the Minister of National Revenue in the computation of the taxable income of the plaintiff. ...
FCTD

Ilori v. Canada (Citizenship and Immigration), 2021 FC 627

Standard of Review [7] Breaches of procedural fairness in administrative contexts have been considered subject to a “reviewing exercise … ‘best reflected in the correctness standard’ even though, strictly speaking, no standard of review is being applied”: Canadian Pacific Railway Company v Canada (Attorney General), 2018 FCA 69 at para 54. ...

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