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Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235; Balthazard v. Canada, 2011 FCA 331, 428 N.R. 329 at paras. 22-24; Helgesen v. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Toronto, ONTARIO   DATE OF HEARING: March 2, 2020   REASONS FOR JUDGMENT BY: MACTAVISH J.A.   ... RENNIE J.A.   DATED: March 25, 2020   APPEARANCES: Jeffrey Radnoff   For The Appellant   Jeremy Tiger For The Respondent   SOLICITORS OF RECORD: Radnoff Law Offices Toronto, Ontario For The Appellant   Nathalie G. ...

Date: 20060614 Docket: A-478-04 Citation: 2006 FCA 220 Present:           SHARLOW J.A. ... Canada [2002] 2 S.C.R. 645. [5]                Finally, the Minister failed to consider the question as to whether or not there was any reason to treat Mr. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET:                                                                               A-478-04 STYLE OF CAUSE:                                                               DENIS LANNO v.                                                                                                 ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235. Consequently, the Judge’s rulings on questions of fact are reviewable on a correctness standard. ... Fitzwilliam, 2002 FCT 598 (CanLII), he stated the following: [51]      Rule 147 allows the Court to consider the documents to be validly served if it is satisfied that the document came to the notice of the person to be served. ... HER MAJESTY THE QUEEN AND 9011‑1345 QUÉBEC INC.   PLACE OF HEARING: Québec, Quebec     DATE OF HEARING: December 17, 2015     REASONS FOR JUDGMENT: NADON J.A.     ...

DAWSON D.J.C.A.   BETWEEN: GWENDOLYN LOUISE DEEGAN and KAZIA HIGHTON   AUTOTEXT   " Blank"   \* MERGEFORMAT Appellants and THE ATTORNEY GENERAL OF CANADA and THE MINISTER OF NATIONAL REVENUE   AUTOTEXT   " Blank"   \* MERGEFORMAT Respondents REASONS FOR JUDGMENT   TOC \o "1-5" \h \z \u WOODS J.A. ... Jarvis, 2002 SCC 73, [2002] 3 S.C.R. 757 in which the Supreme Court made a distinction between audit and investigative materials obtained by the Canada Revenue Agency (CRA). [47] With respect to audit materials, the Court considered s. 8 of the Charter and concluded that “taxpayers have very little privacy interest in the materials and records that they are obliged to keep under the ITA, and that they are obliged to produce during an audit. … [T]here is nothing preventing auditors from passing to investigators their files containing validly obtained audit materials.” ... THE ATTORNEY GENERAL OF CANADA and THE MINISTER OF NATIONAL REVENUE     PLACE OF HEARING: VANCOUVER, BRITISH COLUMBIA     DATE OF HEARING: March 30, 2022     REASONS FOR JUDGMENT BY: WOODS J.A. ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235, at paragraph 37). However, the abuse analysis proceeds in two stages. ... Canada, 2001 FCA 260, [2002] 2 F.C. 288. [34]   There, the liquidator of Standard Trust Company sought to maximize the recovery from the disposition of Standard’s assets. ... ATTORNEY GENERAL OF CANADA     AND DOCKET: A-141-17     STYLE OF CAUSE: PERRY WILD v. ...

MONAGHAN J.A.     BETWEEN:     COLIN WOOD     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard by online video conference hosted by the Registry on February 3, 2022. ... MONAGHAN J.A.     BETWEEN:     COLIN WOOD     Appellant     and     HER MAJESTY THE QUEEN     Respondent   REASONS FOR JUDGMENT MONAGHAN J.A. [1] The appellant, Colin Wood, appeals the Tax Court of Canada’s decision in Wood v. ... Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 [Housen]. II. Overview of Tax Court Decision on Unreported Income [9] The unreported gross revenues (and resulting net business income) in 2011 and 2012 arose from different business activities. [10] Those in 2011 came from two sources: most significantly from SG Marketing and Shivdat Ganesh (the owner of SG Marketing), but approximately $28,000 from other sources. [11] Mr. ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 at para. 8). [13] There have been relatively few cases where the interplay of subsections 115(4) and 119(2) of the OBCA has been examined and none of them are from this Court or the Ontario Court of Appeal. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: April 26, 2022   REASONS FOR JUDGMENT BY: GLEASON J.A.   ... MONAGHAN J.A.   DATED: july 7, 2022   APPEARANCES: Craig J. Allen   For The Appellant   Meaghan Mahadeo Jason Stober   For The Respondent   SOLICITORS OF RECORD: Craig Allen Law Windsor, Ontario   For The Appellant   A. ...

Appellant and HER MAJESTY THE QUEEN Respondent       REASONS FOR JUDGMENT   NOËL J.A ... Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235).   [24]            It is common ground that the determination of a business’ profit under subsection 9(1) of the Act is a question of law and that the profit of a business for a given year is determined by setting against the revenues from the business for that year the expenses incurred in earning said income (M.N.R. v. ... “I agree.         Robert Décary J.A.”   “I agree.         Gilles Létourneau J.A.”         ...

CONCURRED IN BY:                                                                                                         NADON J.A.                                                                                                                                            ... Canada, [2002] T.C.J. No. 63 (T.C.C.) (QL), per Judge Tardif). 1.         ... Nikolaisen, [2002] 2 S.C.R. 235). (e)        Transportation of goods and trucking [50]      The appellant admitted that these expenditures were associated with construction of the cheese house during the 1993 taxation year. [51]      The trial judge was obliged to conclude they were excluded under s. 37(8)(d)(i) of the Act. ...

NADON J.A.                         PELLETIER J.A.   BETWEEN: HER MAJESTY THE QUEEN Appellant and MARTINE LANDRY Respondent             Heard at Montréal, Quebec, on May 18, 2010. ... She therefore underwent a net worth audit for the 1998 to 2002 taxation years. The audit led to approximately $602,627 being added to the respondent’s income, broken down as follows: $91,388 for 1998; $89,146 for 1999; $68,068 for 2000; $181,849 for 2001 and $172,176 for 2002. ...