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FCTD
Gray v. Canada (Attorney General), 2019 FC 1553
Statement to accompany application (2) The application shall include a solemn affirmation or declaration (a) stating the name and address of the applicant; (b) stating that the applicant is at least 18 years old and a resident of Canada; (c) stating the nature of the alleged offence and the name of each person alleged to have contravened, or to have done something in contravention of, this Act or the regulations; and (d) containing a concise statement of the evidence supporting the allegations of the applicant. ...
FCTD
Messenger v. Canada (Attorney General), 2021 FC 95
Messenger stated that two paragraphs of the First Refusal were inconsistent as the CRA officer recognized that the room limits the CRA had provided did not include amounts previously contributed to his TFSA, he was notified after December 31, 2017 of his contravention, and yet his cancellation request was denied. ...
TCC
Daniel Marcoux and Pierre Daneau and Denis Coderre and Raymond Brisson v. Minister of National Revenue, [1991] 1 CTC 2116, [1991] DTC 478
Dans l'esprit des appelants, il est facilement concevable que ces déductions pouvaient inclure toutes les dépenses occasionnées par le fait qu'ils étaient en situation de voyage comme les droits de péage sur les autoroutes, les frais de lavage de camion non payés par l'employeur, les contraventions pour excès de vitesse, les frais pour douches, etc. ...
TCC
Cornerstone Properties Limited v. Her Majesty the Queen, [1995] 2 CTC 2371, 95 DTC 614
We would note that this is a commercial property and affidavit of evidence as to the contravention of the provisions of the Family Law Reform Act is consequently not required in respect of a conveyance from a corporation. ...
TCC
L. Deborah Sword v. Minister of National Revenue, [1990] 2 CTC 2298
They would be unable to interrogate suspects in contravention of the 10(b) rights. 6. ...
FCA
Solvent Petroleum Extraction Inc., Organic Research Inc., Organic Research Limited Partnership, Becker Engineering Limited, Union Farm Equipment, Inc., Seona Wilder, Dara Wilder, Gerald Byerlay, C & C Auto Truck and Equipment Sales Inc., Diversified Machine Tool Inc. And Ronald Johnson v. Minister of National Revenue, [1989] 2 CTC 177
Southam, additional reasons were given by the Ontario Court of Appeal in support of the conclusion that subsection 231(4) was in contravention of section 8 of the Charter. ...
TCC
Boosey and Hawkes (Canada) LTD v. Minister of National Revenue, [1984] CTC 2871, 84 DTC 1728
I do not understand the respondent to have contended that the method adopted by the appellant in computing its income in 1978 was in contravention of any of the provisions of the Income Tax Act nor that the method failed to truly reflect the appellant’s profit or loss for the year. ...
TCC
Thiele Drywall Inc. v. Her Majesty the Queen, [1996] 3 CTC 2208 (Informal Procedure)
The characterization of overtime payments as expenses was a false and deceptive method employed to circumvent the income tax system, in contravention of subsection 239(1)(d) of the Income Tax Act. 13. ...
TCC
McDonald v. R., [1999] 4 CTC 2459 (Informal Procedure)
According to the Tax Court Judge the outside director had, in contravention of the statutory standard of care, failed to “heed what is transpiring within the corporation and his experience with the people who are responsible for the day-to-day affairs of the corporation” (supra at 930, per Rip, J.T.C.C.). ...
T Rev B decision
Robert P Grimson v. Minister of National Revenue, [1977] CTC 2095, 77 DTC 101
On the other hand, if a section of the statute is not only ambiguous and confusing, but an allegedly literal interpretation and application of the law would also have a result which would be contrary to a basic principle of tax law, it would, in my opinion, in such a case be equally unjustifiable to interpret and apply the letter of the law in contravention with the Legislature’s evident intent. ...