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We are in agreement with the learned Trial Division Judge that the imposition of higher rates of taxation on taxpayers of higher income does not contravene section 15 of the Charter. ...

.* [2] As for the contention that the Alternative Minimum Tax provisions are invalid because they contravene the Charter, specifically section 15 thereof, it appears to us, as it appeared to the Tax Court judge, simply untenable. ...

He says that this change has had the effect of discriminating against those whose marginal rate of income tax is in excess of 17%, because the rate of tax credit is limited to 17% regardless of the income of the taxpayer. [2]      We are in agreement with the learned Trial Division Judge that the imposition of higher rates of taxation on taxpayers of higher income does not contravene section 15 of the Charter. ...

In my reasons for judgment in the case of The Minister of National Revenue v Kruger Inc (File No A-l 153-83), which reasons will be filed at the same time as these, I express the view that subsection 231(4) of the Income Tax Act contravenes section 8 of the Constitution Act, 1982 in that it empowers the Minister, when he has reasons to believe that a taxpayer committed an offence under the Income Tax Act, to authorize a search for documents and things that may afford evidence not only of that offence but, also, of the violation of any other provision of the Income Tax Act. ... I would, for these reasons, allow the appeal, set aside the judgment of the Trial Division and declare (1) that subsection 231(4) of the Income Tax Act contravenes section 8 of the Canadian Charter of Rights and Freedoms and 1s, for that reason, inoperative; (2) that the seizures of the appellants’ documents, books and records executed on July 8 and August 9, 1982, pursuant to authorizations issued under subsection 231(4) of the Income Tax Act, were unlawful; and (3) that the appellants are therefore entitled to the return of all documents and things illegally seized on July 8 and August 9, 1982. ...

It is settled law in this Court that paragraph 118.2(2)(n) does not contravene section 15 and that, in the absence of any distinguishing facts, the principles established in Miller v. ...

While it is true that the Charter has imposed upon the Courts the duty to ensure the conformity and compatibility of the laws of Canada with the Charter, it has not endowed the Courts with the power to rewrite these laws, whether they contravene or not the Charter. ...

Nikolaisen, 2002 SCC 33, at paras. 7-37, [2002] 2 S.C.R. 235). [12]            We are of the view that in reaching his conclusion that the application for an extension of time to file the notices of objection must be dismissed, the Judge made no errors of law, fact or mixed fact and law. [13]            We commend the Judge for his efforts in going beyond what was necessary to explain the reasons for his denial of the application, making clear the limitations of the Tax Court of Canada in relation to the Taxpayer’s real complaint and describing other possible venues where she might seek redress for that complaint. [14]            The Appellant has served and filed a Notice of Constitutional Question, raising for the first time a question of the constitutional validity, applicability and effect of subsection 152(9) and sections 166.1, 166.2, 222, 165 and 169 of the Act, on the basis that they contravene sections 7 and 8 of the Canadian Charter of Rights and Freedoms. [15]            In Guindon v. ...

The judge ruled that to hear the appellant’s motion to strike would contravene Rule 8 of the Tax Court of Canada Rules (General Procedure), SOR/90-688a (Tax Court General Procedure Rules). [2]   Colloquially known as the “fresh step rule”, Rule 8 of the Tax Court General Procedure Rules provides: 8  A motion to attack a proceeding or a step, document or direction in a proceeding for irregularity shall not be made, (a)  after the expiry of a reasonable time after the moving party knows or ought reasonably to have known of the irregularity, or (b) if the moving party has taken any further step in the proceeding after obtaining knowledge of the irregularity, except with leave of the Court. [3]   The Tax Court held that both parts (a) and (b) of Rule 8 were met and declined to grant leave for the appellant to file his motion. ...

Holder's shares, combined with the application of subsection 40(3), contravenes subsection 4(4). [10]            The Tax Court Judge concluded that subsection 4(4) has no application in this case because "a contrary intention is evident". ...

Of relevance in this appeal are paragraphs 168(1)(b) and (e), which read as follows: 168. (1) The Minister may, by registered mail, give notice to a person described in any of paragraphs (a) to (c) of the definition “qualified donee” in subsection 149.1(1) that the Minister proposes to revoke its registration if the person 168. (1) Le ministre peut, par lettre recommandée, aviser une personne visée à l’un des alinéas a) à c) de la définition de « donataire reconnu » au paragraphe 149.1(1) de son intention de révoquer l’enregistrement si la personne, selon le cas: … […] (b) ceases to comply with the requirements of this Act for its registration; b) cesse de se conformer aux exigences de la présente loi relatives à son enregistrement; … […] (e) fails to comply with or contravenes any of sections 230 to 231.5; or e) omet de se conformer à l’un des articles 230 à 231.5 ou y contrevient; … […] [35]            Under paragraph 168(1)(b), the Minister is empowered to revoke the registration of a charitable organization if it ceases to comply with its registration requirements. ... Paragraph (b) stipulates that no part of the organization’s income can be payable to, or otherwise available for, the personal benefit of any proprietor, member, shareholder, trustee or settlor of the organization. [37]            Under paragraph 168(1)(e), the Minister is empowered to revoke the registration of a charitable organization that fails to comply with or contravenes any of sections 230 to 231.5. ... As a result, the Appellant argues that the Minister was required to proceed in that fashion and was precluded from pursuing the revocation of the Appellant’s status as a charitable organization. [57]            In response, the Minister offers the following quote from a CRA document entitled “CRA Summary Policy CSP-U02, Undue Benefits”: A registered charity that contravenes or continues to contravene the Act could [in addition to the imposition of a penalty under subsection 188.1(4)] also have its registration revoked. [58]            This quotation does no more than summarize subsection 189(7), which neither party provided to the Court. ...