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MINISTER OF NATIONAL REVENUE and SOPHIE PAYETTE     PLACE OF HEARING: BY ONLINE VIDEOCONFERENCE   DATE OF HEARING: October 26, 2020   REASONS FOR JUDGMENT OF THE COURT BY: NADON J.A. ... LEBLANC J.A.   DELIVERED FROM THE BENCH BY: LEBLANC J.A.   APPEARANCES: Simon-Pierre Hébert   For the appellant   Simon Petit Julien Dubé-Senécal   For the respondent DEPARTMENT OF NATIONAL REVENUE   Mercedes Diaz FOR THE RESPONDENT SOPHIE PAYETTE COUNSEL OF RECORD: BCF LLP Quebec City, Quebec   For the appellant   Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Ontario   For the respondent DEPARTMENT OF NATIONAL REVENUE     ...

HER MAJESTY THE QUEEN     MOTION DEALT WITH IN WRITING WITHOUT APPEARANCE OF PARTIES REASONS FOR ORDER BY: LASKIN J.A.   DATED: April 6, 2018   WRITTEN REPRESENTATIONS BY: David Plotkin   For The Appellants   Pierre McMartin   For The Respondent, gmr inc.   ... Montreal, QC   For The Appellants   Beaudry, Bertrand, s.e.n.c.r.l. Gatineau, QC   For The Respondent, GMR INC.   ...

HER MAJESTY THE QUEEN     PLACE OF HEARING: BY ONLINE VIDEO CONFERENCE   DATE OF HEARING: January 26, 2021   REASONS FOR JUDGMENT OF THE COURT BY: STRATAS J.A. ... MACTAVISH J.A.   DELIVERED FROM THE BENCH BY: WOODS J.A.   APPEARANCES: Shamsher Singh Bhachu   For The Appellant   Jessica Ko   For The Respondent   SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada For The Respondent     ...

CANADIAN HUMAN RIGHTS COMMISSION and CANADIAN ARMED FORCES     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: October 10, 2019   REASONS FOR JUDGMENT OF THE COURT BY: DAWSON J.A. ... GLEASON J.A.   DELIVERED FROM THE BENCH BY: GLEASON J.A. APPEARANCES: David Baker Laura Lepine For The Appellant   Wendy Wright Joseph Cheng   For The Respondents   SOLICITORS OF RECORD: Bakerlaw Barristers & Solicitors Toronto, Ontario   For The Appellant   Nathalie G. Drouin Deputy Attorney General of Canada For The Respondents     ...

Date: 20050113 Docket: A-575-03 Citation: 2005 FCA 16 CORAM:        LÉTOURNEAU J.A. ... Harvey                                                   FEDERAL COURT OF APPEAL                                                       SOLICITORS OF RECORD DOCKET:                                                                   A-575-03 STYLE OF CAUSE:                                                   CLAIRE LACOMBE MORENCY Appellant and ATTORNEY GENERAL OF CANADA Respondent PLACE OF HEARING:                                             Montréal, Quebec DATES OF HEARING:                                             January 13, 2005 REASONS FOR JUDGMENT                                 LÉTOURNEAU J.A. OF THE COURT:                                                       NOËL J.A. ...

THE CORPORATION OF THE CITY OF WINDSOR     PLACE OF HEARING: toronto, ontario   DATE OF HEARING: March 2, 2015   REASONS FOR JUDGMENT BY: STRATAS J.A.   ... SCOTT J.A.   DATED: April 7, 2015   APPEARANCES: Larry P. Lowenstein Laura K. ... Johnson   For The Respondent   SOLICITORS OF RECORD: Osler, Haskin & Harcourt LLP Toronto, Ontario   For The Applicant   Aird & Berlis LLP Toronto, Ontario   For The Respondent     ...

NEAR J.A.     Date: 20171013 Docket: A-245-16 Citation: 2017 FCA 207 CORAM: PELLETIER J.A. ... II.                  Issue [12]            The issue in this appeal is whether the avoidance transaction undertaken by the taxpayer was abusive. ... Drouin Deputy Attorney General of Canada For The Respondent   ...

HER MAJESTY THE QUEEN   DOCKET: A-232-19   PLACE OF HEARING: Vancouver, British Columbia   DATE OF HEARING: February 5, 2020   REASONS FOR JUDGMENT of the court by: RENNIE J.A.   ... LOCKE J.A.   DATED: FEBRUARY 6, 2020   APPEARANCES: Mike DiLalla   for the appellant (ON HIS OWN BEHALF)   Geraldine Chen   For The Respondent   SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada For The Respondent     ...

ATLANTIC TOWING LIMITED et al.     AND DOCKET: A-57-19     STYLE OF CAUSE: HEILTSUK HORIZON MARITIME SERVICES LTD. et al. v. ATLANTIC TOWING LIMITED et al.     AND DOCKET: A-428-19     STYLE OF CAUSE: ATLANTIC TOWING LIMITED v. ... ATLANTIC TOWING LIMITED et al.     AND DOCKET: A-433-19     STYLE OF CAUSE: ATTORNEY GENERAL OF CANADA v. ...

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. ...