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TCC
Abbass v. The King, 2023 TCC 169
The King, 2023 TCC 169 Docket: 2020-854(IT)G BETWEEN: MOSTAFA ABBASS, Appellant, and HIS MAJESTY THE KING, Respondent. ... Gagnon” Gagnon J. Citation: 2023 TCC 169 Date: 20231229 Docket: 2020-854(IT)G BETWEEN: MOSTAFA ABBASS, Appellant, and HIS MAJESTY THE KING, Respondent. ... Luu: … So, here, you mentioned an inflow of money in 2010 and an outflow of money in 2013, correct? ...
TCC
LBL Holdings Limited v. The King, 2023 TCC 130
The King, 2023 TCC 130 Docket: 2012-4371(GST)G BETWEEN: LBL HOLDINGS LIMITED, Appellant, and HIS MAJESTY THE KING, Respondent. ... Cheung JUDGMENT The appeals from the Reassessments dated June 23, 2005, made under the Excise Tax Act (Canada) for the Appellant’s January 1, 1999 to February 29, 2000 GST monthly reporting periods are allowed in accordance with the attached Reasons for Judgment, and the Reassessments are vacated. ... During 1999 to 2000, the Grandview accounts were generally COD – cash before drop. ...
TCC
Total Energy Services Inc., 2024 TCC 12
Pizzitelli” Pizzitelli J. Citation: 2024 TCC 12 Date: 20240202 Docket: 2016-367(IT)G BETWEEN: TOTAL ENERGY SERVICES INC., Appellant, and HIS MAJESTY THE KING, Respondent. ... V Canada 2005 SCC 54 (“Canada Trustco”) at par 22 and Copthorne Holdings Ltd. ... AND HIS MAJESTY THE KING PLACE OF HEARING: Calgary Alberta Edmonton, Alberta DATE OF HEARING: June 20-24, 2022 & June 27-29, 2022 January 15, 2024 & January 16, 2024 REASONS FOR JUDGMENT BY: The Honourable Justice F.J. ...
TCC
Vasilkioti v. The King, 2024 TCC 101
The King, 2024 TCC 101 Docket: 2020-979(IT)G BETWEEN: MARILYN VASILKIOTI, Appellant, and HIS MAJESTY THE KING, Respondent. ... SCHEDULE A CITATION: 2024 TCC 101 COURT FILE NO.: 2020-979(IT)G STYLE OF CAUSE: MARILYN VASILKIOTI v. ... For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada ...
FCTD
Jacobson Holdings Ltd. v. The Queen, 85 DTC 5634, [1986] 1 CTC 87 (FCTD)
I agree with the learned trial judge that a clear and unequivocal positive act implementing a change of intention would be necessary to change the character of the land in question from a trading asset to a capital asset — and that on the facts here present, there was no evidence of such a positive or overt act. ... M.N.R., [1984] C.T.C. 2005; 84 D.T.C. 1752 where it was said that acceptance by the Minister of expenses incurred in connection with the use of land as a “restricted farming loss” amounted to an admission that the land in question was being used as a capital asset in a business. ...
TCC
Claude Lamothe v. Her Majesty the Queen, [1996] 3 CTC 2423 (Informal Procedure)
.: — In these appeals, which concern assessments for the 1991, 1992 and 1993 taxation years, the issue is the Minister of National Revenue’s refusal to allow the appellant a tax credit for a severe and prolonged mental or physical impairment pursuant to sections 118.3 and 118.4 of the Income Tax Act. ... R., [1996] 2 C.T.C. 2005 (T.C.C.), at page 6 [of original], I said: I should also say something about approach that this Court should take in these disability cases. ...
TCC
Les Soudures Chagnon Ltée v. Minister of National Revenue, [1990] 1 CTC 2365, 90 DTC 1203
He referred the Court to definitions of the word "contingent" in French and English dictionaries; in French, the Dictionnaire Robert defines the word "contingent" as meaning, inter alia, ”... eventual, fortuitous, accidental, uncertain... conditional", the Dictionnaire Bélisle gives the following definition "What may or may not happen, v. accidental, casual, conditional, eventual, fortuitous, uncertain, chance...”. ... & R. Enterprises Ltd., [1979] C.T.C. 465; 79 D.T.C. 5399, the services rendered by the employees were rendered for several years without immediate payment on condition that the final remuneration was determined at the end of the year. ... M.N.R., [1981] C.T.C. 2005; 81 D.T.C. 21. Secondly, the Court held that the payment of the bonuses depended on whether the necessary funds were available. ...
TCC
Dias v. The Queen, 2021 TCC 85
The Appellants relied primarily on two cases. [27] The first is the 2005 decision of Chief Justice Bowman in Borys v. ... Graham” Graham J. CITATION: 2021 TCC 85 COURT FILE NOS.: 2018-3473(IT)G 2018-3474(IT)G STYLES OF CAUSE: XAVIER DIAS v THE QUEEN WENDY DIAS v THE QUEEN PLACE OF HEARING: Toronto, Ontario DATES OF HEARING: October 19 and 20, 2021 REASONS FOR JUDGMENT BY: The Honourable Justice David E. ... Pniowsky Firm: Thompson Dorfman Sweatman LLP For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada ...
FCTD
Groupmark Canada Ltd. v. The Queen, 93 DTC 5179, [1993] 1 CTC 234 (FCTD)
The Queen, [1980] C.T.C. 57, 80 D.T.C. 6009, dealing with exchange rates, Addy, J. stated at pages 59-60 (D.T.C. 6011): The word “ payable” does not normally mean “paid”. ... M.N.R., [1990] 2 C.T.C. 2005, 90 D.T.C. 1499 in the Tax Court dealing with monthly alimentary payments to be made by the husband to the wife to be set off against $20,000 which she owed him for his interest in the matrimonial home which monthly payments he sought to deduct from his income and were added to hers, the agreement having been ratified in Court, it was held that this did not constitute payment within the meaning of the Income Tax Act. ...
FCTD
Grandmont v. Canada (Attorney General), 2023 FC 1765
An application for judicial review is not an appeal (Paiani v Canada (Minister of Citizenship and Immigration), 2005 FC 514 at para 1). [27] There is therefore no doubt that, in its judicial review to determine the reasonableness and legality of the Decision, the Court cannot examine Ms. ... DATED: December 28, 2023 APPEARANCES: Janie Grandmont FOR THE APPLICANT ON HER OWN BEHALF Samantha Jackmino FOR THE RESPONDENT SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT ...