11,311 result(s)
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9,626.
Gray v. The Queen - 2016 TCC 54 - 2016-03-08
Tax Court of Canada JudgmentsHowever, he found that TACS was outrageously expensive for what was seemingly a fairly simple tax return. [...] He continued to deal with FA since he did not know who else to turn to. [...] [19] Counsel for the Appellant has done a great deal of research and has supplied a book of authorities for my guidance.
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9,627.
Attaran v. Canada (Attorney General) - 2015 FCA 37 - 2015-02-03
Federal Court of Appeal DecisionsThe pre-Dunsmuir jurisprudence of this Court dealing with judicial review of Commission decisions dismissing complaints pursuant to paragraph 44(3)(b) of the Act supports such a formulation: Sketchley v. Canada (Attorney General), 2005 FCA 404, [2006] 3 F.C.R. 392. [...] [...] g) le fait qu’un fournisseur de biens, de services, d’installations ou de moyens d’hébergement destinés au public, ou de locaux commerciaux ou de logements en prive un individu ou le défavorise lors de leur fourniture pour un motif de distinction illicite, s’il a un motif justifiable de le faire. [...] The Minister of Citizenship and Immigration, in the management of his portfolio, made efforts to deal with a backlog that existed.
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9,628.
9114-4766 Québec Inc. v. The Queen - 2015 TCC 25 - 2015-02-02
Tax Court of Canada JudgmentsJean Renaud said that a great deal of effort was put forward in objecting to the Minister's refusal to allow the appellants’ claim of the provincial tax credit. [...] [64] Gartry v. Canada, [1994] T.C.J. No. 240 (QL), 94 DTC 1947, deals with the issue of whether a taxpayer has begun operating a business. [...] Each case turns on its own facts, but where a taxpayer has taken significant and essential steps that are necessary to the carrying on of the business it is fair to conclude that the business has started. . . .
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9,629.
Olympia Trust Company v. The Queen - 2014 TCC 372 - 2014-12-19
Tax Court of Canada Judgments2. The fair market value and consideration of each Preferred Share of the Company shall be $1.00 in accordance with the Articles of the Company, a copy of the relevant section of which is attached hereto for reference. [...] is deemed not to include an arrangement under which the trust can reasonably be considered to act as agent for all the beneficiaries under the trust with respect to all dealings with all of the trust’s property unless the trust is described in any of paragraphs (a) to (e.1) of the definition “trust” in subsection 108(1). [...] beneficiaries under the trust with respect to all dealings with all of the trust’s property (unless the trust is described in any of paragraphs (a) to (e.1) of the definition “trust” in subsection 108(1)), ceases to act as agent for a beneficiary under the trust with respect to any dealing with any of the trust’s property,
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9,630.
Elbadawi v. The Queen - 2014 TCC 259 - 2014-08-27
Tax Court of Canada JudgmentsThe appeals involved income from multiple corporations, inter-corporate dealings and a plethora of claimed expenses. [...] [35] The Appellant, Mohammed Elbadawi, argued that the family members loaned a great deal of money to 526 Ontario and that the CRA mischaracterized these funds as revenue. [...] While the Respondent placed a great deal of weight on the fact that Waleed attended the New Home Warranty Tribunal hearing in a representative capacity for Mobilsa, I believe his attendance and actions in this regard were simply pursuant to the direction of his father.
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9,631.
Global Cash Access (Canada) Inc. v. The Queen - 2012 TCC 173 - 2012-05-18
Tax Court of Canada JudgmentsGlobal deals with VISA and Mastercard credit card associations and has merchant status under the rules of these associations. [...] [...] [43] Section 139 of the Act deals with circumstances in which a financial service is supplied with a non-financial service for a single consideration. [...] (iv) monitoring another person’s payment record or dealing with payments made, or to be made, by the other person,
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9,632.
Velcro Canada Inc. v. The Queen - 2012 TCC 57 - 2012-02-24
Tax Court of Canada JudgmentsIn short the dividend is for the owner's own benefit and this person is not accountable to anyone for how he or she deals with the dividend income. ... [...] I will deal with the words "beneficial ownership". While the Appellant re-acquired possession of the property in 1994 it did not obtain title or ownership until 1995 when it was granted a Quit Claim Deed. [...] Only if the interest in the item in question gives that party the right to control the item without question (e.g. they are not accountable to anyone for how he or she deals with the item) will it meet the threshold set in Prévost.
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9,633.
Qin v. Canada (Citizenship and Immigration) - 2012 FC 9 - 2012-01-04
Federal Court DecisionsThe RPD’s analysis of whether the Applicant could practise her religion and worship as she wishes in Tianjin is a fairly conventional one. [...] I repeat what I said in Yang, above, when dealing with similar issues involving an applicant from Fujian: [...] 42 Second, Justice Zinn in Yu, above, at paragraphs 31 and 32, provides further guidance on the facts before me, even though I am dealing with Guangdong and not Fujian Province:
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9,634.
JAG Flocomponents N.A. v. Archmetal Industries Corporation - 2010 FC 627 - 2010-06-10
Federal Court DecisionsHis evidence also covered the events up to and including termination of the business relationship with Archmetal and Jerome Chen as well as some of the aspects of the post-termination phase of dealings. [...] However, the Defendants’ conduct in this regard, in terms of its dealings with the Trade-marks Office, was more egregious. [...] a) faire une déclaration fausse ou trompeuse tendant à discréditer l’entreprise, les marchandises ou les services d’un concurrent;
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9,635.
Pfizer Canada Inc. v. Apotex Inc. - 2009 FC 671 - 2009-06-26
Federal Court DecisionsAs noted by Prothonotary Mylczynski in her decision, “[s]ection 6(5)(b) of the Regulations provides a kind of safety valve to deal with pointless applications that serve only to keep a generic competitor off the market for a little longer” (Pfizer Canada Inc. v. Apotex Inc., 2009 FC 250, at para. 3). [...] [28] On the strength of these conclusions, Prothonotary Milczynski refused to deal with the other issues raised by Pfizer relating to the validity of the NOAs, the possibility to amend Form Vs, and various estoppel arguments. [...] I will deal in turn with each of these aspects. [65] At the outset, it is fair to say that the claims of the ‘278 patent have not yet been construed by this Court.
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9,636.
DatEx Semiconductor Incorporated v. M.N.R. - 2007 TCC 189 - 2006-12-13
Tax Court of Canada Judgments[22] Unlike many provisions of the EIA and the CPP and their Regulations, the provisions in each of these regimes dealing with employees working outside Canada are not parallel provisions. [...] I think it is fair to say then that the first two payments were not only generated from the home office but it is also the case that the administration of the payment process was there. [...] [49] In the case at bar, I am dealing with nothing more than a circumstantial variation in the method or mechanics of payment.
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9,637.
Agustawestland International Ltd. v. Canada (Public Works and Government Services) - 2006 FC 767 - 2006-06-15
Federal Court DecisionsI will deal first with the motion for summary judgment regarding the Minister's decision of July 23, 2004 that the contract be awarded to Sikorsky. [...] [32] The motion for summary judgment regarding the RFP Structure deals with a claim based upon the allegedly biased structure of the RFP dated December 17, 2003. [...] 6. (1) Sous réserve des paragraphes (2) et (3), le fournisseur potentiel qui dépose une plainte auprès du Tribunal en vertu de l'article 30.11 de la Loi doit le faire dans les 10 jours ouvrables suivant la date où il a découvert ou aurait dû vraisemblablement découvrir les faits à l'origine de la plainte.
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9,638.
Brillon v. The Queen - 2006 TCC 76 - 2006-02-09
Tax Court of Canada Judgments• in the three cases, although the projects deal with subjects that are fundamentally different from each other, the documentation provided is strictly identical and bears not the slightest relevance to the subject of the project in which the partner invested funds, [...] We are not dealing with the engagement of an employee, of a person under contract of any kind or of a volunteer. [...] We are dealing with the involvement of a partner in the activities of the partnership of which he or she is a member.
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9,639.
Bastide v. Canada (Attorney General) - 2005 FC 1410 - 2005-10-14
Federal Court Decisionsg) le fait qu'un fournisseur de biens, de services, d'installations ou de moyens d'hébergement destinés au public, ou de locaux commerciaux ou de logements en prive un individu ou le défavorise lors de leur fourniture pour un motif de distinction illicite, s'il a un motif justifiable de le faire. [...] The Commission was given a good deal of latitude and discretion in its decision-making. [...] While it is not an absolute requirement that employee be individually tested, the employer may not satisfy the burden of proof of establishing the reasonableness of the requirement if he fails to deal satisfactorily with the question as to why it was not possible to deal with employees on an individual basis by, inter alia,
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9,640.
Roth v. The Queen - 2005 TCC 484 - 2005-08-02
Tax Court of Canada JudgmentsQ. Have you seen any evidence on any document that would lead you to conclude that Ray Roth did not deal with Tri Pacific at arm’s length in 1993? [...] Q. That’s a fair way of characterizing it? A. Yes. ANALYSIS AND CONCLUSIONS [...] The arm’s length aspect led Appellant’s counsel to conclude that the value of what was transferred by Roth to Tri Pacific was irrelevant, a deal having been made for the sum of $370,000.
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9,641.
Canada (Correctional Services) v. Yeager - 2003 FCA 30 - 2003-01-22
Federal Court of Appeal DecisionsAccordingly, the order fails to deal with the five issues dealt with in the reasons. [...] I will deal with the issues in the cross-appeal later. Factual Background [...] [13] I deal first with the respondent's requested Data. The evidence is that they do not exist but could be recreated.
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9,642.
Telus Advanced Comminications v. Telecommunications Workers Union - 2002 FCA 310 - 2002-09-09
Federal Court of Appeal Decisions[21] [...] There is nothing, aside from the context in which these were negotiated, to indicate that the parties meant to do more or less than deal with the stumbling block that was before them at the time. [...] [23] Although the Board distinctly raised the issue of possible employees east of Alberta being affected by the order, no party was willing to deal with issue directly at that time. [...] b) faire l'objet d'un recours judiciaire, notamment par voie d'injonction, de certiorari, de prohibition ou de quo warranto.
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9,643.
Re-Directions Inc. v. M.N.R. - 2001-09-17
Tax Court of Canada JudgmentsIn addition, counsel for the appellant and counsel for the respondent agreed the pleadings filed in appeal 2000-3809(EI) would be used - generally - for the purpose of dealing with all appeals pursuant to the Act. [...] Penner stated he did not consider this procedure to be fair to the workers and - later - was able to negotiate with Phase Four for them to be paid a cancellation fee. [...] The Field Technicians were not experienced in dealing with servers but were more accustomed to working on personal computers.
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9,644.
Bayer Ag v. Apotex Inc. - 1998-11-03
Federal Court Decisions[14] For ease of reference, I have identified seven issues argued before me, five of which I will deal with as preliminary issues and two of which I describe as substantive issues. [...] [12] Mr. Justice Lutfy, who was dealing with the third notice of allegation brought by Apotex in respect of ciprofloxacin, noted: [...] We believe that " 119 and " 102(d) deal with unrelated concepts and that these two provisions cannot be read together.
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9,645.
Hodgson v. Musqueam Indian Band - 2017 FC 509 - 2017-05-18
Federal Court Decisions• (7) Mr. Neufeld’s Calculation of the “Fair Rent” [156] VI. Analysis [...] [157] Calculating the “fair rent” for each lot at 6% of its market value in an unserviced state as of the valuation date, Mr. Neufeld arrived at “fair rents” for the Musqueam Park properties ranging from $115,804 to $226,616 per annum. [...] The methodology used to arrive at the current market value and fair rent for each of the plaintiffs’ lots should also be applied to each of these lots in order to arrive at the current market value and fair rent for the Third Party Leaseholders’ lots.
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9,646.
Astrazeneca Canada Inc. v. Apotex Inc. - 2015 FC 322 - 2015-03-16
Federal Court DecisionsHowever, since Apotex largely rested its case on the patent disclosure, I will then deal with Apotex's argument based on the disclosure. [...] The videos depict a fairly rapid disintegration of a film-like layer. [...] The need for scrupulous accuracy and fair dealing under the NOC system is manifest.
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9,647.
Complexe Enviro Progressive Ltée v. Canada (Transport) - 2018 FC 1299 - 2018-12-21
Federal Court DecisionsAn entire section of the Regulations deals with wildlife planning and management at “airports” as well as with the requirements for the wildlife management plan that airport operators must develop. [...] CEPL adds that, in the circumstances, this way of dealing with the risk after the fact and leaving it to the eventual operators of the aerodrome constitutes an unlawful renunciation of the Minister’s duty. [...] a) d’une part, celle-ci peut faire l’objet d’un règlement sur la sûreté aérienne;
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9,648.
Canada (Office of the Information Commissioner) v. Calian Ltd. - 2017 FCA 135 - 2017-06-22
Federal Court of Appeal Decisions[14] As for the history of the parties’ dealings, the Judge found that it was both of the parties’ intention to treat and consider the personnel rates as exempt. [...] [16] On the issue of the impact of the Disclosure Clause, the Judge found that it was but one factor to be taken into consideration when determining what “could reasonably be expected” under paragraph 20(1)(c) of the Act, in conjunction with, for instance, the history of the dealings between the parties. [...] Fairness among bidders requires consistency and predictability. [59] As a matter of fact, the clear language of a contract must always prevail over the surrounding circumstances, even when interpreting a negotiated contract.
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9,649.
Pfizer Canada Inc. v. Canada (Attorney General) - 2009 FC 719 - 2009-07-10
Federal Court DecisionsAt the same time, Parliament strengthened the Board’s mandate to deal with the price abuse that could potentially result from the monopolies that it had created. [...] Paragraph 4(4)(a) deals with the reporting of the average price per package in respect of each dosage form, and provides that: [...] 82. (1) Tout breveté doit, dès que possible après avoir fixé la date à laquelle il compte mettre en vente sur un marché canadien un médicament qui n’y a jamais été vendu, notifier le Conseil de son intention et de la date à laquelle il compte le faire.
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9,650.
Abbott Laboratories v. Canada (Minister of Health) - 2005 FC 1095 - 2005-08-10
Federal Court Decisions[8] Thus, in order to deal with this case, this Court must construe claims 15 and 20 of the '732 Patent. [...] Neither the text, nor the formula indicate that it deals with a solvate. [...] [53] The expert evidence suggests that it is customary for chemists to indicate in the formula and in the text if they are dealing with solvates.