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Barry considered was not the $182,779 established by his expert, Mr. Silas, and that Mr. ... Barry considered the opening balance of the shareholder account on November 1, 2001, to be nil. ... Therefore, the $54,840 amount cannot be considered a contribution of capital from QuébecCo’s shareholder. ...

Employment at CRA should be considered a constitutional right. [17] The social contract between Mr. ... The Amended Claim does not disclose any material fact regarding the mobility rights provided for by section 6(2)(b) of the Charter, so this provision should not even be considered on the merits of this case. [17] To establish a breach of section 15, a plaintiff must demonstrate: (a) the existence of a distinction based on enumerated or analogous grounds, on its face or in its impact, and (b) that such distinction imposed a burden on or denied a benefit in a manner that has the effect of reinforcing, perpetuating, or exacerbating disadvantage (R v Sharma, 2022 SCC 39 at para 28). [18] The Plaintiff has now made some reference to these essential elements in the Amended Claim. ... “Jocelyne Gagné” Judge   FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-2129-24   STYLE OF CAUSE: ISAAC OLUSEGUN v HIS MAJESTY THE KING   MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES ORDER AND REASONS: GAGNÉ J.   ...

The CIF represents the amount of the insurer’s investment property that is considered to be used in the Canadian insurance businesses at the end of the year. ... It did not. [92] It appears that a special rule may have been considered but not adopted. ... This separation might be considered to give rise to an inference that the World Surplus assets are not necessary to the Appellant’s insurance business. ...

Costs can only be considered from the time litigation is initiated. [underlining added] [9]                In my respectful view, the Crown is in error in relying upon the comments of Mr. ... There is no reason for the respondents to subsidize by a reduced award of costs whatever public interest might exist in having the legislation judicially considered. 6. ... Column III level costs are considered to address a case of average complexity (see Rule 407). ...

Having considered the submissions of both parties, I cannot conclude, based on the record before me, that Kameron has met the high threshold set by the CBC decision for mandatory interlocutory injunctions. [30]   While this conclusion is sufficient to dispose of the matter, in consideration of the arguments put forward by the parties I will also examine the other elements of the test. ... The factors which must be considered in assessing this element of the test are numerous and will vary with the circumstances of each case: RJR-MacDonald, at 342. [41]   The harm to be assessed is that which will occur between the date of the grant (or refusal) of the interlocutory injunction and the decision on the underlying application. ... Pentney” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: IMM-261-18 STYLE OF CAUSE: KAMERON COAL MANAGEMENT LTD. v THE MINISTER OF EMPLOYMENT AND SOCIAL DEVELOPMENT CANADA MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES JUDGMENT AND REASONS: PENTNEY J. ...

Campbell J. found it was unreasonable for the RAD to have considered only the first option was plausible, as there was no “verifiable evidentiary base” to support the second inference, and granted the judicial review: He 2017, above at paras 10-11. [26]   In contradistinction, the Minister asserts the RAD reasonably was entitled to rely on the fact the Applicants were not stopped at the airport as proof they were not actually Falun Gong practitioners: He v Canada (Citizenship and Immigration), 2019 FC 728 [He 2019], above at paras 12-15. ... Unlike in He 2017 (at para 9), however, the RAD in this case did not fail to consider the possible alternative inferences altogether, but rather considered and concluded inferences 2 and 3 were not plausible: 1) The Falun Gong group was raided but the Applicants were not implicated because Ms. ... In this case, the RAD has considered that it found the Appellants not to be credible in regard to "being wanted by the authorities at the time they exited China; that the Appellants testified that they learned about the PSIB visits while in contact with family via video chat; and that they have not provided documentation regarding these conversations even though they were able to provide the principal Appellant’s girlfriend’s we chat page, which shows that they have the capacity to acquire this sort of information. [38]   The RAD indicated the need for corroborative documentation because it found the Applicants were not credible. ...

Given this obligation, it is difficult to see how a taxpayer’s ignorance about the fact that RRSP contributions are subject to a limit could be considered reasonable. ... As the respondent noted, each taxpayer’s circumstances must be considered objectively (Connolly, at para 69) and it appears that CRA did so. ... The letter showed that CRA considered the applicant’s circumstances and her position on why her tax liability should be waived. [54] CRA’s letter recognized that the applicant did not intend to make excess contributions. ...

The Appellant relied on Reference re Goods and Services Tax, [1992] 2 S.C.R. 445, suggesting it stands for the principal that two provisions or sets of provisions can be considered together in the constitutional analysis to support its position. ... At most, he states “This option is what is being considered [emphasis mine] in all cases where the Advantage Tax has been assessed on abusive transactions that occurred before October 17, 2009”. ... I agree with the Appellant that the practical effect of the tax imposed by 207.05 is to discourage certain specific transactions involving TFSAs that are considered abusive and with the Respondent that section 207.05 has no effect outside the TFSA regime, does not apply generally to all savings or investment accounts and so is limited to what is in pith and substance taxation. 4.   ...

Cases Cited   Considered:   Continental Bank Leasing Corp. v. Canada, [1998] 2 S.C.R. 298, rev’g [1996] 3 F.C. 713; distinguished:   Spire Freezers Ltd. v. ... They considered the evidence of the Canadians’ intentions and conduct in relation to each of the assets owned by the Commons at the material times.  ... That the alleged partnership must be considered in the totality of the circumstances prevents the mechanical application of a checklist or a test with more precisely defined parameters.    ...

Specific findings made in the detailed and carefully considered reasons for judgment of Justice MacKay were: i.           ... No. 4352, Sedgwick J. of the Ontario Court of Justice (General Division) considered the purpose of the equivalent provision of the Ontario Courts of Justice Act, R.S.O. 1990, c. ... FACTORS TO BE CONSIDERED [51]            As for the factors to be considered when an application is brought pursuant to subsection 40(1) of the Act, in Vojic v. ...