11,309 result(s)
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526.
Madsen v. The Queen - 1998-03-23
Tax Court of Canada JudgmentsThe Income Tax Act, he says, deal with individuals, not with partnership. [...] (a) where a taxpayer has acquired anything from a person with whom he was not dealing at arm’s length at an amount in excess of the fair market value thereof at the time he so acquired it, he shall be deemed to have acquired it at that fair market value. [...] That is whether the Minister erred in reassessing to reduce the $6.850M to $422,000.00, the latter being the fair market value.
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527.
Envision Credit Union v. The Queen - 2010 TCC 353 - 2010-06-29
Tax Court of Canada JudgmentsAnd that this was the type of correspondence, that it would have been useful or helpful for both Delta and First Heritage to cooperate on; is that a fair summary? [...] So is it fair to say that others in the organization, such as Tom Webster, for example, may have had more dealings with FICOM directly, and may have participated in drafting this letter, for example? [...] I guess - - yes, I guess that's a fair description. Q Okay. Prior to the amalgamation, discussions were commenced.
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528.
Kreutzweiser v. Canada (Attorney General) - 2018 FC 46 - 2018-01-17
Federal Court DecisionsDoes the CDS have authority to deal with the Applicant’s harassment complaint? [...] 29.11 The Chief of the Defence Staff is the final authority in the grievance process and shall deal with all matters as informally and expeditiously as the circumstances and the considerations of fairness permit. [...] [84] In dealing with the reinstatement request, the CDS concluded as follows:
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529.
CanHorizon Inc. v. M.N.R. - 2015 TCC 19 - 2015-01-23
Tax Court of Canada JudgmentsHowever, while in China, she attended an education fair in Shanghai on behalf of the Appellant, although the Appellant was not employing or paying for the Worker’s services. [...] (a) related persons shall be deemed not to deal with each other at arm’s length; [...] It is a departure from common sense that goes against the grain of what is procedurally fair and just.
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530.
Wentzell v. M.N.R. - 2003 TCC 521 - 2003-09-17
Tax Court of Canada JudgmentsIf it is a substantially similar contract of employment, Parliament has deemed it to be only fair that it should be included in the scheme. [...] (v) the Payor and the Appellant did not deal with each other at arm's length; [...] [24] Robert, on behalf of his wife, has raised the question of fairness and whether it is fair that he should have to stack up on his own against 62,000 employees in the Federal Department of Justice.
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531.
Villalobos v. Canada (Minister of Citizenship and Immigration) - 1999-05-28
Federal Court DecisionsMEMBER SACHADENA: Well, yes, because what we've been trying to -- to focus on in the -- in the time constraints have been with respect to dealing with testimony that we find repetitious. [...] A full and fair hearing does not mean an opportunity for a person to go on and on and on. [...] [21] I note that under the CRDD Rules, Rule 28(9) provides that in dealing with a motion the Refugee Division "on being satisfied that no injustice is likely to be caused, may dispose of a motion without a hearing".
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532.
Hawco v. Canada (Attorney General) - 1998-06-12
Federal Court DecisionsSubsequently, on December 18, 1992, the Base Commander completed additional observations dealing principally with the applicant's objections to the notice of intent that he be released. [...] [26] The respondent submits that the standards of procedural fairness were met in this case. [...] [37] Further, I find that there has been no breach of the standards of procedural fairness in this matter.
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533.
Paletta v. The Queen - 2019 TCC 205 - 2022-04-05
Tax Court of Canada JudgmentsAre there any secret deals? A. What's a secret deal? Q. A deal that was not supposed to be disclosed as part of the closing binders. [...] Q. So you know that there's a deal in respect of Puppy Production and a deal in respect of Savage Beagle? [...] (i) the fair market value of the gift is certified by the Minister of the Environment,
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534.
Carpenter Fishing Corporation v. Canada - 1996-11-14
Federal Court DecisionsBruce Turris: Well, it's a double edged sword, how the appeal process may deal with this. [...] I think it's fair to try and draw a fair line than to draw a hard line. [...] So it's fair to the people that have bought and sold and it's fair to the whole fleet.
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535.
Dmitrienko v. Canada (Attorney General) - 2023 FC 1678 - 2023-12-12
Federal Court DecisionsThe Applicant asserts VAC erroneously relied on the chapter dealing with hypertension and vascular impairment (Table 13), as opposed to that dealing with cardiorespiratory impairment (Table 12). [...] Did the Reconsideration Panel breach the duty of procedural fairness? [...] [41] Thus, while the Applicant seeks to make a procedural fairness argument, the Respondent rightly points out that the Applicant’s arguments do not deal with procedure.
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536.
Talbot v. Canada (Citizenship and Immigration) - 2012 FC 972 - 2012-08-07
Federal Court DecisionsIn addition, under subsection 162(2) of the Act, the Board is to deal with all proceedings as quickly as the circumstances and the considerations of fairness and natural justice permit. [...] This provision requires boards to deal with all proceedings as quickly as the circumstances and the considerations of fairness and natural justice permit. [...] 162.(2) Each Division shall deal with all proceedings before it as informally and quickly as the circumstances and the considerations of fairness and natural justice permit.
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537.
Bergeron v. Canada (Attorney General) - 2015 FCA 160 - 2015-07-07
Federal Court of Appeal DecisionsRather, other administrative decision-makers are allowed to deal with human rights issues. [...] The reasons do not deal with all of the matters she raised in her submissions. [...] (2) The procedural fairness issue: the thoroughness of the investigation
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538.
Hillier v. Agc - 2001 FCA 197 - 2001-06-11
Federal Court of Appeal Decisions2. Does the fairness provision contained in subs. 220(3.1) apply to interest accrued as a result of delays in dealing with the appellant's notices of objection? [...] 3. Did the Minister's delegate take into account all relevant considerations in deciding whether to apply the provisions of the fairness provisions of the Income Tax Act? [...] Does Subsection 220 (3.1) Allow the Minister to Waive or Cancel Interest Accrued While Dealing With the Appellant's Notices of Objection
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539.
Francis v. Canada (Citizenship and Immigration) - 2012 FC 1141 - 2012-10-24
Federal Court Decisions1) Did the RPD breach procedural fairness by not communicating to the Applicant the [...] A new panel will be able to deal with all relevant issues including the ones mentioned above. [...] 2. The matter is referred to a new panel in order to deal with all the issues; and
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540.
Wood v. The Queen - 2008 TCC 311 - 2008-05-26
Tax Court of Canada JudgmentsThe original deal was to be closed on April 2002 but did not close until late May 2002. [...] These entries disclose the financial aspect of the deal – the Blackville Property had a cost base of $8,725.59. [...] We however are concerned with the fair market value of the property on May 28, 2002.
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541.
2753-1359 Québec Inc. v. Canada - 2010 FCA 32 - 2010-01-27
Federal Court of Appeal Decisions(c) a person with whom the person was not dealing at arm’s length, the following rules apply: [...] (i) the amount, if any, by which the fair market value of the property at the time it was transferred exceeds the fair market value at that time of the consideration given for the property, and [...] [5] The fact that a transfer was made between persons who were not dealing at arm’s length is not contested.
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542.
Vasilkioti v. The King - 2024 TCC 101 - 2024-07-30
Tax Court of Canada Judgments(c) a person with whom the person was not dealing at arm’s length, the following rules apply: [...] A person with whom the transferor was not dealing at arm’s length. 4) The fair market value of the property transferred must exceed the fair market value of the consideration given by the transferee. [...] The fair market value of this consideration was at least equal to the fair market value of the 50% interest in the Property at the time of transfer, namely $240,498.
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543.
Soullière v. Canada (Blood Services) - 2017 FC 689 - 2017-07-17
Federal Court DecisionsThe Commission should deal with the complaint because it is not frivolous. [...] breaching procedural fairness by i. relying on an inadequate investigation, and [...] She asserts this does not meet the standard of thoroughness required for procedural fairness.
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544.
Richter v. Canada (Citizenship and Immigration) - 2008 FC 806 - 2008-06-26
Federal Court DecisionsAt trial, her defence was that she had been unwittingly drawn into the illegal dealings of her husband, that she had believed the weapons were deactivated and that she was not familiar with firearm mechanics. [...] Issues of procedural fairness, however, are subject to an assessment of whether the procedure was fair; if that duty is found to have been breached, the decision will be vacated. [...] 1. Is there a greater duty of fairness required of immigration officers preparing a section 44(1) report and the Minister in referring the report when dealing with persons in custody?
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545.
Campbell v. The Queen - 2009 TCC 431 - 2009-09-09
Tax Court of Canada JudgmentsBecause they are spouses of each other, they were not dealing at arm’s length. [...] (a) related persons shall be deemed not to deal with each other at arm's length; [...] A person with whom the transferor was not dealing at arm's length. 4) The fair market value of the property transferred must exceed the fair market value of the consideration given by the transferee.
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546.
Forrest v. Canada (Solicitor General) - 1998-10-13
Federal Court DecisionsIn dealing with that requested relief, the issues that are addressed in these reasons are: [...] In holding that there was no breach of procedural fairness, the Québec Court of Appeal commented that [...] The standards by which procedural fairness is measured are not immutable.
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547.
Stagg v. Canada (Attorney General) - 2019 FC 630 - 2019-05-09
Federal Court DecisionsIt also argues that the decision was not made in a procedurally fair manner. [...] The decision challenged deals with the provision of services to members of First Nations. [...] It is easier to deal first with the complaints regarding procedural fairness.
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548.
Petro-Canada v. The Queen - 2002-12-06
Tax Court of Canada Judgments[3] The reassessment now under appeal is based upon assumptions made by the Minister that Phillips (and its related companies) did not deal at arm's length with the Phillips JEC, and that CanEagle did not deal at arm's length with the CanEagle JEC in the purchases and sales of the seismic data, and that the total fair [...] Minister's assumed fair market value #1 - purchased by Phillips JEC December 1991 [...] As with the two sales of copies, a great deal that is relevant is not known about these 20 transactions.
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549.
Sokolowski Romar v. The Queen - 2012 TCC 104 - 2012-04-25
Tax Court of Canada Judgments(c) a person with whom the person was not dealing at arm's length, the following rules apply: [...] A person with whom the transferor was not dealing at arm's length. 4) The fair market value of the property transferred must exceed the fair market value of the consideration given by the transferee. [...] All that is required is that the husband should so deal with the property as to divest himself of it and vest it in his wife, that is to say, pass the property from himself to her.
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550.
Abbas-Nejad v. Canada (Citizenship and Immigration) - 2013 FC 318 - 2013-03-27
Federal Court DecisionsIn my view, given the failure of the IAD to deal with it, its negative conclusion cannot be considered reasonable. [...] Whether the IAD proceeded fairly or unreasonably in respect of her father’s application will have no effect on that application. [...] In particular, the fairness issue is a novel one, so far as I am aware, and deciding it would require the Court to set a precedent.