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Signed at Ottawa, Canada, thi s 25th da y o f July 2012.        "Lucie Lamarre" Lamarre J.   ... Elizabeth Tan, Translator         Citation: 2012 TCC 267 Date: 20120725 Docket: 2010-2000(GST)I BETWEEN: Giuseppe cappadoro, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ...   [56]         The appeal is therefore dismissed, with costs for the respondent.     ...

Appendix I   1.         Is there a technical risk or uncertainty? …   2.         ... …   4.         Did the process result in a technological advance, that is to say an advancement in the general understanding? …   5.         Although the Income Tax Act and the Regulations do not say so explicitly, it seems self-evident that a detailed record of the hypotheses, tests and results be kept, and that it be kept as the work progresses.         ...

Those steps consist in ascertaining: 1.             Whether there is a “ tax benefit ” arising from a “ transaction ” under subsections 245(1) and (2). 2.             ... Rather, relevant provisions are related ‘ because they are grouped together ’ or because they ‘ work together to give effect to a plausible and coherent plan ’ (R.  ... (“GP16”) and GP Co 18 Inc. (“ GP18 ”); (b)   OPGI Office LP and GP16 formed RAC Limited Partnership (“ RAC LP ”) under the LPA. ...

Sommerfeldt” Sommerfeldt J.         Citation: 2017 TCC 85 Date: 20170519 Docket: 2014-2607(IT)G BETWEEN: VICTOR GOREV, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Kardachov’s alleged repayments to make the Subject Deposits, I have combined Tables 5 and 7, so as to set out a chronological sequence showing the repayments and the deposits in 2007 and 2008, as follows: [67] Table 8       Date Alleged Repayment Subject Deposit     January 4, 2007 $7,000     April 2, 2007   $1,000   April 25, 2007   5,500   August 15, 2007 5,000 4,000   August 19, 2007 6,750     August 20, 2007   4,000   September 6, 2007 4,000 2,300   October 30, 2007 6,250 5,000   Total for 2007 $29,000 $21,800   January 31, 2008 $4,500 $1,000 April 15, 2008   2,500 April 28, 2008 6,000   Date Alleged Repayment Subject Deposit April 29, 2008   4,000 May 3, 2008   1,500 May 12, 2008 5,000 5,000 June 27, 2008 4,000   July 9, 2008 5,000 4,000 August 13, 2008 5,000 4,000 November 25, 2008 5,500_____ Total for 2008 $35,000 $22,000 Mr. ... Sommerfeldt DATE OF JUDGMENT: May 19, 2017   APPEARANCES:   Counsel for the Appellant: David M. ...

., Appellant, and HIS MAJESTY THE KING, Respondent.   The Honourable Gabrielle St-Hilaire, Chief Justice   ORDER ON COSTS In accordance with the attached Reasons for Order, the Appellants collectively are awarded costs of $36,518.31, plus disbursements of $1,725.20 for a total of $38,243.51. ... Paragraph 147(3)(b) – amounts in issue [19] The parties disagree on the amounts in issue. ... Neilson   Firm: Felesky Flynn LLP 2610, 10111 – 104 Ave NW Edmonton, Alberta T5J 0J4   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   ...

The Appellant’s financial results included the following, shown in Canadian dollars: 1999 Year   Revenues $38,876,749 Gross margin $9,396,094 Income from operations $43,377 Other income (no dividend from SII) $24,108 Income before taxes $67,485     2000 Year   Revenues $44,650,187 Gross margin $13,557,642 Income from operations $450,290 Other income (no dividend from SII) $1,988,037 Income before taxes $2,438,237     2001 Year   Revenues $54,440,728 Gross margin $17,431,267 Income from operations ($748,018) Other income (no dividend from SII) $5,560,931 Income before taxes $4,812,913 [110]    In both the 2000 and 2001 taxation years, the marketing fees paid to SII were the largest expense on the Appellant’s income statements. [67] [111]    Paragraphs 54-56 of the Statement of Agreed Facts show that SII’s financial results in 1999, 2000, and 2001 included the following (US$): 1999 Year     Revenue       Marketing fees $755,701 Expenses   ($674,986)   Net Income $80,715       2000 Year     Revenue       Marketing fees $2,850,174   Interest $5,072 Expenses   ($1,453,341)   Net Income $1,401,905       2001 Year     Revenue       Marketing fees $5,236,186   Interest $5,309 Expenses   ($1,847,106)   Net Income $3,394,119 [112]    SII’s pre-tax profits from 1999 to 2001 totalled US$4,876,739 (approximately CAD$7.3 million). [68] [113]    According to its 1999 through 2001 Barbados corporate tax returns, SII paid total income taxes in Barbados of US$121,985, as follows [69]: 1999 $2,086 2000 $35,047 2001 $84,952 TOTAL $121,985 [114]    It is an agreed fact that commencing in April 2000, SII began declaring and paying quarterly dividends to the Appellant as follows, shown in US dollars: 2000 Year     April 24 $75,000   August 15 $675,000   December 15 $600,000   Total $1,350,000 (Cdn $2,011,50)       2001 Year     May 31 $360,000   July 26 $375,000   October 22 $175,000   December 31 $2,525,956   Total $3,435,956 (Cdn $5,299,620) [115]    Mr. ... Csumrik and Longview •          Resale Price method •          Cost Plus method 2. ...   [73]          Transcript, page 1081, lines 1-9. [74]          Exhibit A-2, page 2, paragraphs 1.1(f)(i)(4-15). [75]          Transcript, page 568. [76]          Transcript, page 1038, line 16. [77]          Transcript, page 328, lines 1-7. [78]          Transcript, page 1035, lines 9-10. [79]          Transcript, page 890, line 28 to page 891, line 10. [80]          Transcript, page 323, lines 3-17. [81]          Transcript, page 1074, line 20. [82]          Transcript, page 1123, lines 7-21. [83]          Exhibit A-1, Tabs 34 and 35. [84]          Transcript, page 317, lines 12-17. [85]             Transcript, page 1098, line 22 to page 1099, line 6. [86]          Transcript, page 1126, lines 4-7. [87]          Exhibit A-1, Tabs 34 and 35. [88]          Transcript, page 317, lines 8-10. [89]          Canada v. ...

Cartier was paid “ by the job ” as opposed to Mr. Ahern’s compensation which was “ by the hour. ” [5]              I would comment at the outset that Mr. ... Ahern be an independent contractor. [28]         The appeal will be allowed.          ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Meberatu explained that Prohome / We Care paid her a motor vehicle allowance of $0.20 / km and that S.R.T. ... Meberatu in her returns.                                           ii.             ... Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]           2010:  $6,744.38 total expenses / 25,500 km total driving = $0.2645 / km 2011:  $6,651.77 total expenses / 25,500 km total driving = $0.2609 / km 2012:  $6,712.30 total expenses / 25,000 km total driving = $0.2685 / km [2]           $0.20 paid by employer  / $0.2646 average cost over three years = 75.58% [3]           My quick review of the 21 receipts found on the first six pages of receipts indicates that approximately 14% of the purchases were purchases of lottery tickets, not gas. [4]           2015 TCC 314. ...

Smith” Smith J.   Citation: 2024 TCC 90 Date: 20240617 Docket: 2021-1679(IT)I BETWEEN: JEAN-MARIE ROBILLARD, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Canada, 1997 2 S.C.R. 336 (“ Hickson Motors ”). Those principles were later summarized by the Federal Court of Appeal in House v. Canada, 2011 FCA 234 (“ House v. Canada ”) as follows: The burden of proof in taxation cases is that of the balance of probabilities. ...

I will sometimes refer to these three witnesses as the “ CRA witnesses ”. [10]         Mr.  ... Voluntary Disclosure Program Submission Fiscal Years 2002 to 2006 ” (the “ VDP Document ”). ... Underdown and the title “ vice president & chief financial officer ”. [50]         On December 2, 2010 at 1:56 p.m., Mr.  ...