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TCC

994552 N.W.T. Ltd. v. The King, 2025 TCC 55

The 2010 and 2011 Audit #2 begins Skolney & Co present [15] During 2012, Skolney & Co engaged with CRA representatives to conclude and deploy their practical and logical plan, assented to by Zoran. ... Bocock DATE OF JUDGMENT: April 17, 2025   APPEARANCES:   Counsel for the Appellant: Robert A. ... Neilson   Firm: Felesky Flynn LLP For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     [1] Income Tax Act, RSC 1984, c 1 (5 th Supp), s. 152(4)(a)(i) [The Act]. [2] Francis & Associates v. ...
TCC

2078970 Ontario Inc. v. The Queen, 2017 TCC 173

the Amended Reply for each of the two Appeals;                                                             iii.       ...       [31]          The Applicants’ factum shall be filed and served 30 days prior to the scheduled hearing date. ... Tyron Counsel for the Respondent: Michael Taylor Raj Grewal   COUNSEL OF RECORD: For the Appellant: Name:     Firm:     For the Respondent: Nathalie G. ...
TCC

Yao v. The King, 2024 TCC 19 (Informal Procedure)

COMMON REASONS FOR JUDGMENT TABLE OF CONTENTS   TOC \o "1-5" \u I. ...   [32] In May 2017, Ms. Zhang claimed refugee protection under the IRPA. ... Bocock   DATE OF JUDGMENT: February 15, 2024 APPEARANCES: Co-Counsel for the Appellant: Alexander Cobb Andrew Boyd Graeme Rotrand Ada Chan Jackie Chiu Counsel for the Respondent: Arnold Bornstein Alexander Hinds Laoura Christodoulides   Counsel for the Intervenor Nabila Qureshi Adrian Merdzan Anu Bakshi COUNSEL OF RECORD: For the Appellant: Alexander Cobb Andrew Boyd Graeme Rotrand Firm: Osler Hoskin & Harcourt LLP     Ada Chan Jacky Chiu Firm: Chinese and Southeast Asian Legal Clinic For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   For the Intervenor: Adrian Merdzan Nabila F. ...
TCC

Cooper v. The Queen, docket 97-2694-IT-I (Informal Procedure)

Assessment audit reassessment [10] The Appellant was assessed for the 1991 taxation year on the basis that he was entitled to a deduction for the ABIL as claimed in his return. ... The ABIL to which the Appellant is entitled, therefore, is properly computed as: 100 shares at $1.00 each    $100.00 paid to the bank $213,949.18 less recovered from Locke 48,463.50 165,485.68 removal expenses 52,892.84 total    218,478.52 ABIL = 0.75 x $218,478.52 = $163,858.89 This is $689.11 less than the amount claimed by the Appellant. ... Bowie" J.T.C.C. [1]           Exhibit R-8, supra. [2]            [1983] 1 S.C.R. 29 at 39. ...
TCC

Porotti v. M.N.R, 2014 TCC 267

Woods” Woods J.       Citation: 2014 TCC 267 Date: 20140905 Dockets: 2013-2800(CPP) 2013-2801(EI)   BETWEEN:   MICHELLE POROTTI, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.   ... Woods DATE OF JUDGMENT: September 5, 2014   APPEARANCES:   For the Appellant: The Appellant herself   Counsel for the Respondent:   Holly Popenia   COUNSEL OF RECORD: For the Appellant: Name: N/A   Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Ontario     ...
TCC

Lipson v. The Queen, 2006 DTC 2687, 2006 TCC 148, aff'd supra.

The approach to s. 245 of the Income Tax Act may be summarized as follows.         1.    ... The burden is on the taxpayer to refute (1) and (2), and on the Minister to establish (3).        3.    ... On September 1, 1994, the following transactions occurred:                  (i)       the Transfer/Deed of Land, showing the Appellant and Jordanna Lipson as joint tenants, was registered;                  (ii)       the Charge/Mortgage of Land was registered;                  (iii)      the Appellant's solicitor used the funds received from the Appellant on August 31, 1994 to pay $562,500 towards the purchase price of the Property;                  (iv)      the Bank advanced $562,500 to the Appellant's solicitor in trust as proceeds from the mortgage on the Property;                  (v)      the Appellant's solicitor used the $562,500 proceeds from the mortgage to repay Jordanna Lipson's loan from the Bank; 13.     ...
TCC

9114-4766 Québec Inc. v. The Queen, 2015 TCC 25 (Informal Procedure)

  [9]              Jean Renaud is the instigator of the entire project that led to the incorporation of the appellants. ...   [39]         A paper copy of the software and of one company’s Web site was filed (Exhibit A-2). ...   [84]         It seems to me from the testimony that the appellants did have some desire to start a business. ...
TCC

Chiang v. The Queen, 2017 TCC 165 (Informal Procedure)

As illustrated by that table, the amounts of Part X.1 tax assessed by the CRA for 2006 and 2011 through 2013 were less than the amounts of Part X.1 tax calculated by the Court.       ... Sommerfeldt DATE OF JUDGMENT: August 31, 2017   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Derek Edwards   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]           Income Tax Act, RSC 1985, c. 1 (5th supplement), as amended. [2]               Mr. ...
TCC

Canadian Imperial Bank of Commerce v. R., [1997] 3 C.T.C. 2819, 97 D.T.C. 1362

Respondent's Position Gold and Silver Bullion 23 The Respondent concedes that the first two requirements set out in paragraph 20(1)(gg) of the Act are not in issue. ... Thus when the income of a vending business is calculated in accordance with the well recognized formula used in inventory account: Gross Profit = Proceeds of Sale- Value of Inventory at the beginning of the year + Cost of Inventory acquisitions- Value of Inventory at the end of the year, or: Gross Profit = (Proceeds of Sale- Value of Inventory Sold) + Change in Value of Unsold Inventory. the value of unsold inventory appears as a cost item. and contends that the value of the Appellant's physical gold and silver bullion does not appear as a cost item in the calculation of its income in the relevant fiscal period. ... Minister of National Revenue Respondent's Position Foreign Currency 35 It is the Respondent's position that “tangible property” and “intangible property” are not mutually exclusive concepts. ...
TCC

Peyramaure v. The Queen, 2005 TCC 633 (Informal Procedure)

Elizabeth Tan, Translator CITATION:                                        2005TCC633 COURT FILE No.:                             2005-1509(IT)I STYLE OF CAUSE:                           Gabriel Peyramaure v. Her Majesty the Queen PLACE OF HEARING:                      Québec, Quebec DATE OF HEARING:                        September 15, 2005 REASONS FOR JUDGMENT BY:     The Honourable Justice Alain Tardif DATE OF JUDGMENT:                     September 29, 2005 APPEARANCES: For the Appellant: The Appellant himself Counsel for the Respondent: Yanick Houle COUNSE L OF RECO RD:        For the Appellant:        For the Respo ndent:                     John H. Sims, Q.C.                                                           Deputy Attorney General of Canada                                                           Ottawa, Ontario ...

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