PRATIQUE
Limitation of Actions
Judicial review of decision by M.N.R. refusing applicant’s request residence of applicant trust be settled in accordance with para. 4 of Art. IV of Convention Between Canada and The United States of America With Respect to Taxes on Income and on Capital (Sch. 1 to Canada-United States Tax Convention Act, 1984, S.C. 1984. c. 20)—Court having jurisdiction to deal with application for judicial review, mandamus—Application time-barred under Federal Courts Act, R.S.C., 1985, c. F-7, s. 18.1(2), premature as not in respect of “decision”—Application dismissed.
Perry v. M.N.R. (T-2206-06, 2007 FC 1071, Gibson J., order dated 18/10/07, 21 pp.)
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