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REASONS FOR ORDER BY: RENNIE J.A.   Date: 20191022 Docket: A-244-19 Citation: 2019 FCA 257 Present:   RENNIE J.A. ... DATED: OCTOBER 22, 2019   WRITTEN REPRESENTATIONS BY: Douglas C. Hodson   For The Appellant   Forrest C. Hume Monique Evans   For The Respondent, Freight Management Association of Canada   Lucia M. ...

That was the problem raised in Mark Resources Inc. v. /?., [4] as in Canwest Broadcasting Ltd. v. /?.. ... He bases the latter requirement — the net income concept — on Mr. Justice Pigeon’s decision in Quebec (Deputy Minister of Revenue) v. ... In addition, a table the respondent provided shows that for the years in question, an investor derived, with respect to the taxation of his or her in- come, no tax benefit from the fact that the borrowed amounts had been invested in offshore companies instead of Canadian companies [73] ^: Dividend Gross-Up & Tax Credit (Individuals) Dividend Deduction- Part 1 (Corporations) Basis of Examples • Incremental income of $1,000 • Income is interest income (investment income) • Income is not subject to withholding tax ° CCPC: Canadian Controlled Private Corporation ¢ NR Corporation not resident in Canada not subject to income tax in any jurisdiction Facts • Individual tax rates (Federal) 47% (max) ITA 117(5) • Dividend gross-up: A of the dividend paid: subsection 82(1) of the Income Tax Act • Dividend Tax Credit: A of gross-up: section 121 • Dividend Refund: lesser of RDTH and ’A dividend paid ¢ RDTH Refundable Portion of Part I Tax plus Part IV Tax payable minus dividend refunds of previous years • Refundable Portion of Part I Tax: 25% of Investment Income (simplified) • Part IV Tax: *A of Taxable Dividends received from Taxable Canadian corporations Assumptions • Corporate Tax Rate: 50% Federal + Provincial combined ° Individual Tax Rates (Provincial) 30% of Federal Tax Sections 82- Dividend Gross-Up and Sections 121 Dividend Tax Credit Individuals Income from a: CCPC NR Income 1,000 1,000 Less Income from a: CCPC NR Tax Payable @ 50% SOO Net Income after Tax 500 I OOO Plus Dividend Refund 250 Refundable Part I (25% of income) Available for Dividend 750 1,000-, Dividend Received by Individual 750 1,000 Gross-up (’A of the dividend) 250 Section 82 of the Income Tax Act Taxable Income 1,000 1,000 — — —■ ■- Federal Tax @ 47% 470 470 Less Dividend Tax Credit (A x Gross-up) 200 Federal Tax Payable 270 470 Plus Provincial Tax Payable 30% of Fed. 8 I 141 Total Tax Payable 351 611 After Tax Income Dividend Received 750 1,000 Less Tax Payable 35] 611 — After Tax Income 399 389 Section 112-Dividend Deduction Ludco Income from a: CCPC NR Income 1,000 1,000 Less Tax Payable @ 50% 500 Net Income after Tax 500 1,000 Plus Dividend Refund 250 Refundable Part I (25% of Income) Available for Payment of Dividend 750 1,000 — ■■ ■ », — — ■ » ■■ Dividend Received by Ludco 750 1,000 Income from a: CCPC NR Tax Payable Part I 500 Part IV 250 — — Net Income After Tax 500 500 Plus Dividend Refund Refundable Part I (25% of Income) 250 Part IV 250 — ■ ' Available for Payment of Dividend 750 750 In short, neither the investment in offshore companies nor the interest expense the appellants incurred unduly or artificially reduced their income. ...

For services of counsel I claim the following: (a) preparation of notice of appeal, $ 244,67 (b) preparation of hearing, $ 246,10 (c) conducting the hearing (1/2), $ 287.50 (One half day) (d) for taxation of costs, $ nil B. For witnesses fees I claim the following: $ nil C. For expert witnesses I claim the following: $ 400,00 D. ... (See, also, Donald Campbell & Co. v. Pollack, [1927] A.C. 732 (U.K. ...

MACTAVISH J.A.   BETWEEN: ATTORNEY GENERAL OF CANADA Appellant and IRIS TECHNOLOGIES INC. ... MACTAVISH J.A.     Date: 20211122 Docket: A-164-21 Citation: 2021 FCA 223 CORAM: RENNIE J.A. ... IRIS TECHNOLOGIES INC.     PLACE OF HEARING: Ottawa, Ontario   DATE OF HEARING: October 21, 2021   REASONS FOR JUDGMENT BY: RENNIE J.A.   ...

REASONS FOR ORDER BY: MONAGHAN J.A.   Date: 20250314 Docket: A-314-24 Citation: 2025 FCA 62 Present: MONAGHAN J.A. ... ATTORNEY GENERAL OF CANADA     MOTION Dealt with in writing without appearance of parties REASONS FOR ORDER BY: MONAGHAN J.A.   DATED: March 14, 2025   WRITTEN REPRESENTATIONS BY: Therese Lennert   For The Appellant (ON HER OWN BEHALF)   No émie Vespignani   For The Respondent   SOLICITORS OF RECORD: Shalene Curtis-Micallef Deputy Attorney General of Canada For The Respondent     ...

HER MAJESTY THE QUEEN   DEALT WITH IN WRITING WITHOUT APPEARANCE OF PARTIES REASONS FOR ORDER: LEBLANC J.A.   ... RIVOALEN J.A.   DATED: September 4, 2020   WRITTEN REPRESENTATIONS: Roumène Bonev   For the appellant (representing himself) Julien Wohlhuter Vlad Zolia For the respondent   SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada For the respondent     ...

The appeal will be dismissed with costs.                           "Marc Noël"                                                                   J.A. ... Respondent PLACE OF HEARING:                     Montréal, Quebec DATE OF HEARING:            April 6, 2005 REASONS FOR JUDGMENT:       NOËL J.A. CONCURRED IN BY:                      LÉTOURNEAU J.A. NADON J.A. DATE OF REASONS:            April 6, 2005 APPEARANCES: Daniel Bourgeois/Nicolas Simard                                               FOR THE APPELLANT André P. ...

FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-310-19     STYLE OF CAUSE: HER MAJESTY THE QUEEN (as represented by the Minister of National Revenue in her capacity as Minister responsible for the Income Tax Act), CANADA REVENUE AGENCY and THE ATTORNEY GENERAL OF CANADA     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: April 25, 2022   REASONS FOR JUDGMENT BY: GLEASON J.A.   ... RIVOALEN J.A.   DATED: august 19, 2022   APPEARANCES: J. Randall Barrs   For The Appellant   Andrea Jackett For The Respondents SOLICITORS OF RECORD: J. Randall Barrs Toronto, Ontario   For The Appellant   A. François Daigle Deputy Attorney General of Canada For The Respondents     ...

RENNIE J.A.     BETWEEN: HER MAJESTY THE QUEEN Appellant and OXFORD PROPERTIES GROUP INC. ... Drouin Deputy Attorney General of Canada   For The APPELLANT   Osler, Hoskin & Harcourt LLP Toronto, Ontario For The Respondent     ...

REASONS FOR ORDER BY: LEBLANC J.A.   Date: 20250331 Docket: A-245-24 Citation: 2025 FCA 75 Present: LEBLANC J.A. ... MINISTER OF NATIONAL REVENUE   MOTION DEALT WITH IN WRITING WITHOUT APPEARANCE OF PARTIES REASONS FOR ORDER BY: LEBLANC J.A.   DATED: March 31, 2025   WRITTEN REPRESENTATIONS BY: Adam Aptowitzer   For The Appellant   Linsey Rains Alex Nguyen Mengjiao Liu   For The Respondent   SOLICITORS OF RECORD: KPMG Law LLP Ottawa, Ontario   For The Appellant   Shalene Curtis-Micallef Deputy Attorney General of Canada   For The Respondent     ...