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FCA

Hokhold v. Canada, 2018 FCA 163

BOIVIN J.A.   BETWEEN: DR. FRANK CH. HOKHOLD Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT BOIVIN J.A. [1]   This is an appeal from a decision of Paris J. ... " I agree M. Nadon J.A." "I agree David Stratas J.A. FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-388-17   STYLE OF CAUSE: DR. ... Drouin Deputy Attorney General of Canada For The Respondent   ...
FCA

Negus v. Canada, 2019 FCA 159

RIVOALEN J.A.     BETWEEN: RUSSELL NEGUS Appellant and HER MAJESTY THE QUEEN Respondent Docket: A-412-18 AND BETWEEN: JEAN-MARC BOUGIE Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on May 23, 2019. ... There is nothing to suggest that they cannot do so now. [5]   The appeals will therefore be dismissed with costs. [6]   These reasons shall apply to the appeals in file A-411-18 and 412-18. ... Drouin Deputy Attorney General of Canada For The Respondent   ...
FCA

Van Steenis v. Canada, 2019 FCA 107

He observed that, under the scheme, distributions of capital unlike distributions of income are not taxed in the hands of the unitholder until they exceed the amount invested. ... Van Steenis’s appeal. [7]   Mr. Van Steenis now appeals to this Court. ... Drouin Deputy Attorney General of Canada For The Respondent   ...
FCA

Goheen v. Canada, 2019 FCA 104

REASONS FOR JUDGMENT OF THE COURT BY: RENNIE J.A.   Date: 20190501 Docket: A-126-18 Citation: 2019 FCA 104 CORAM: STRATAS J.A. ... RENNIE J.A. [1]   This is an appeal from a judgment of the Tax Court of Canada (2018 TCC 62, per Lyons J.). ... Drouin Deputy Attorney General of Canada For The Respondent   ...
FCA

Levy v. Canada, 2021 FCA 93

WEBB J.A.   BETWEEN: ELIAS LEVY Appellant and HER MAJESTY THE QUEEN Respondent Heard by online video conference hosted by the registry on May 12, 2021. ... Nadon” J.A.   FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKETS: A-349-19, A-350-19, A-351-19 AND A-95-20   STYLE OF CAUSE: ELIAS LEVY v. ... Drouin Deputy Attorney General of Canada For The Respondent   ...
FCA

Elm Ridge Country Club Inc. v. Minister of National Revenue, [1999] 3 CTC 163

Ratti write at p. 6-1 that “income from property” means [TRANSLATION] [...] the return on invested capital when neither the taxpayer entitled to it nor any of its agents has devoted much effort, time or attention to generating the income [...] ... There are two important exceptions to this principle [...] One arises where the securities held constitute an integral part of the taxpayer’s other business activities; the other, where the taxpayer’s investment activities are such that they amount in themselves to the conduct of a separate business [...] ... This presumption is very far-reaching [...] The legislature is presumed to have a mastery of existing law, both common law and statute law. as well as the case law interpreting statutes. ...
FCA

Libfeld v. The King, 2023 FCA 235

HECKMAN J.A.   BETWEEN: COREY LIBFELD Appellant and HIS MAJESTY THE KING Respondent Heard at Toronto, Ontario, on November 30, 2023. ... REASONS FOR JUDGMENT OF THE COURT BY: HECKMAN J.A.   Date: 20231130 Docket: A-200-22 Citation: 2023 FCA 235 CORAM: GLEASON J.A. ... “Gerald Heckman” J.A.   FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-200-22   STYLE OF CAUSE: COREY LIBFELD v. ...
FCA

Gloglo v. Canada (National Revenue), 2024 FCA 13

HECKMAN J.A.   BETWEEN: MIDJOHODO FRANCK GLOGLO Appellant and MINISTER OF NATIONAL REVENUE Respondent Heard at Montréal, Quebec, on January 16, 2024. ... REASONS FOR JUDGMENT OF THE COURT BY: HECKMAN J.A.   Date: 20240116 Docket: A-225-22 Citation: 2024 FCA 13 CORAM: BOIVIN J.A. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-225-22   STYLE OF CAUSE: MIDJOHODO FRANCK GLOGLO v. ...
FCA

KAM-PRESS METAL PRODUCTS LTD. v. HER MAJESTY THE QUEEN, 2021 FCA 88

BOIVIN J.A.   Date: 20210510 Docket: A-442-19 Citation: 2021 FCA 88 CORAM: WEBB J.A. ... BOIVIN J.A.   BETWEEN: KAM-PRESS METAL PRODUCTS LTD. Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT WEBB J.A. [1] Kam-Press Metal Products Ltd. ... Drouin Deputy Attorney General of Canada For The Respondent   ...
FCA

Astro Consulting Inc. v. Canada, 2023 FCA 248

DAWSON D.J.C.A.   BETWEEN: ASTRO CONSULTING INC. Appellant And HIS MAJESTY THE KING Respondent Heard at Edmonton, Alberta, on December 19, 2023. ... REASONS FOR JUDGMENT OF THE COURT BY: WEBB J.A.   Date: 20231219 Docket: A-134-22 Citation: 2023 FCA 248 CORAM: STRATAS J.A. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-134-22   STYLE OF CAUSE: ASTRO CONSULTING INC. v. ...

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