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FCTD
Murphy v. Canada (National Revenue), 2009 FC 1226
[76] The Applicants placed considered emphasis upon Fjoser’s powerpoint presentation which he gave to various police forces from time to time. ...
FCTD
Vaillancourt v. Vaillancourt, 2007 FC 1294
I also considered that fact that the judgment debtor was uneducated, although this in no way changes the fact that before he died, besides his property at issue he did not possess any other valuable assets that enabled him to pay his debt to the judgment creditor. ...
FCTD
Productions Espace vert VIII inc. (Mission Gibbons à Bornéo) v. Canada (Canadian Heritage), 2011 FC 1522
He stated that [translation] “a representative of the Canadian producer did in fact telephone me several months ago to inquire about the balance of CNC funding of films in production and I provided her with an answer on this point; as for the rest, I considered it, perhaps a bit perfidiously, to be their business. ...
FCTD
Canada (National Revenue) v. Kerby, 2008 FC 452
Other elements to be considered are the following: a. the fine must not be a mere token amount, but must reflect the ability of the person found in contempt to pay the fine; b. ...
FCTD
General Motors of Canada Limited v. Canada (National Revenue), 2013 FC 1219
Recognizing that neither GMCL nor Program Employees had kept such records, the Minister stated that “an approximation could have been considered using appointment calendars, expense reports or other sources”. ...
FCTD
Velimirovic v. Canada (Citizenship and Immigration), 2019 FC 1156
This can also be considered a correct or reasonable analytical approach. ...
FCTD
Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2020 FC 893
., 2019 SCC 4, [Metro Vancouver] at para 4. [57] Blue Bridge also suggests that the CRA has admitted that in the case of a discretionary trust, a person is considered a beneficiary only when he or she directly or indirectly receives a discretionary distribution from the trust. [58] A decision from the Administrative Court of Appeal of Paris has allegedly also recognized that the assets of an Anglo-Saxon trust are separate from the asset base of the beneficiary, in addition to confirming that the trustee is the one who has ownership of the trust’s assets: Administrative Court of Appeal, No. 16PA01660, Paris, October 12, 2017. ...
FCTD
Special Risk Holdings Inc. v. Her Majesty the Queen and Minister of National Revenue, [1994] 1 CTC 274, 94 DTC 6151
I think it’s quite clear and if this is not a sufficient admission for my friend, we can talk about it some more, but up to and including the careful review of this proposal by Verchere, when he suggested a two-step approach to the 51/49, nobody considered anything other than 51/49, neither Mr. ...
FCTD
Maurice Moloney, Raymond L. Young, Gary A. Russell and Steven S. Fullard v. The Queen, [1989] 1 CTC 213, 89 DTC 5099
It might perhaps be said that it met the "busi ness" test and the "reasonable expectation of profit” test if only Canadian operations are considered. ...
FCTD
Canada (National Revenue) v. Miller, 2021 FC 851
I have considered the Minister’s request and the factors set out in Rule 400(3) in light of the mixed result in this application and will award costs to the Minister in the amount of $1,250.00. ...