Bonnybrook Industrial Park Development Co. Ltd. v. Canada (National Revenue)

JurisdictionFederal Jurisdiction (Canada)
CourtCourt of Appeal (Canada)
Citation2018 FCA 136
Date18 July 2018

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30 practice notes
  • Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
    • Canada
    • Irwin Books The Federal Court of Appeal and the Federal Court. 50 Years of History
    • October 4, 2021
    ...to the SCC refused [2015] SCCA No 68 [ ConocoPhillips ]; Bonnybrook Industrial Park Development Co Ltd v Canada (National Revenue) , 2018 FCA 136. 47 See inter alia Ereiser , above note 38; ConocoPhillips , above note 46; Roitman , above note 27; Johnson , above note 27 ; Walsh , above note......
  • Canada (National Revenue) v. Shopify Inc., 2025 FC 968
    • Canada
    • Federal Court (Canada)
    • May 29, 2025
    ...for a UPR request. They are precise and unequivocal (see Bonnybrook Park Industrial Development Co Ltd v Canada (National Revenue), 2018 FCA 136 at para 34 [Bonnybrook], citing Canada Trustco Mortgage Co v Canada, 2005 SCC 54 at para 10 [Canada [36] In this vein, courts operate on the presu......
  • Entertainment Software Assoc. v. Society Composers
    • Canada
    • Court of Appeal (Canada)
    • June 5, 2020
    ...v. Canada (Attorney General), 2014 FCA 193 at para. 4 and Bonnybrook Park Industrial Development Co. Ltd. v. Canada (National Revenue), 2018 FCA 136, 44 Admin. L.R. (6th) 71 at paras. 87-94. Where reasons read in light of the record “contain a fundamental gap or reveal that the decision is ......
  • Sharif v. Canada (Attorney General)
    • Canada
    • Court of Appeal (Canada)
    • November 13, 2018
    ...Agency), 2015 FCA 263, 479 N.R. 189; and see discussion in Bonnybrook Industrial Park Development Co. Ltd. v. Canada (National Revenue), 2018 FCA 136 at paras. 80-83 (dissenting reasons, but not opposed by the majority on this point). This demarcation is underscored by subsection 43(3) of t......
  • Get Started for Free
28 cases
  • Entertainment Software Assoc. v. Society Composers
    • Canada
    • Court of Appeal (Canada)
    • June 5, 2020
    ...v. Canada (Attorney General), 2014 FCA 193 at para. 4 and Bonnybrook Park Industrial Development Co. Ltd. v. Canada (National Revenue), 2018 FCA 136, 44 Admin. L.R. (6th) 71 at paras. 87-94. Where reasons read in light of the record “contain a fundamental gap or reveal that the decision is ......
  • Canada (National Revenue) v. Shopify Inc., 2025 FC 968
    • Canada
    • Federal Court (Canada)
    • May 29, 2025
    ...for a UPR request. They are precise and unequivocal (see Bonnybrook Park Industrial Development Co Ltd v Canada (National Revenue), 2018 FCA 136 at para 34 [Bonnybrook], citing Canada Trustco Mortgage Co v Canada, 2005 SCC 54 at para 10 [Canada [36] In this vein, courts operate on the presu......
  • Canada (National Revenue) v. Shopify Inc., 2025 FC 969
    • Canada
    • Federal Court (Canada)
    • May 29, 2025
    ...for a UPR request. They are precise and unequivocal (see Bonnybrook Park Industrial Development Co Ltd v Canada (National Revenue), 2018 FCA 136 at para 34 [Bonnybrook], citing Canada Trustco Mortgage Co v Canada, 2005 SCC 54 at para 10 [Canada [23] In this vein, courts operate on the presu......
  • Alexion Pharmaceuticals Inc. v. Canada (Attorney General)
    • Canada
    • Court of Appeal (Canada)
    • July 29, 2021
    ...2014 FCA 114, 372 D.L.R. (4th) 567 at para. 33; Bonnybrook Park Industrial Development Co. Ltd. v. Canada (National Revenue), 2018 FCA 136; 44 Admin. L.R. (6th) 71 at paras. 89-94 in dissent. As well, we were concerned that “in trying to sustain an outcome reached by flawed reasoning, [revi......
  • Get Started for Free
1 books & journal articles
  • Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
    • Canada
    • Irwin Books The Federal Court of Appeal and the Federal Court. 50 Years of History
    • October 4, 2021
    ...to the SCC refused [2015] SCCA No 68 [ ConocoPhillips ]; Bonnybrook Industrial Park Development Co Ltd v Canada (National Revenue) , 2018 FCA 136. 47 See inter alia Ereiser , above note 38; ConocoPhillips , above note 46; Roitman , above note 27; Johnson , above note 27 ; Walsh , above note......