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The Queen, 2014 TCC 370     Docket: 2012-2894(IT)G BETWEEN: GURCHARANJIT BUDWAL, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Truscott COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada   [1]   $149,054 x 60% = $89,432 for G. ...

That does not, however, change the fact that the Share Purchase Agreement had the effect of essentially making her a party. [39]          Transcript, pg. 249, lines 1 to 7. [40]          First Endorsement, para. 3. [41]          First Endorsement, para. 8. [42]          First Endorsement, paras. 9 to 11. [43]          First Endorsement, para. 16. [44]          2006 FCA 353. [45]          2011 FCA 79. [46]          2013 FCA 11. [47]          2013 TCC 310. [48]          Those documents include statements that Mr. ... Plummer was a shareholder (Exhibit R-1, Tab 7, para. 34). [49]          Transcript pg. 410, lines 7 to 19. [50]          Amended Reply, para. 14(k). [51]          Exhibit A-1, Tab 40. [52]          Transcript, pg. 247, line 25 to pg. 248, line 9. [53]          Exhibit A-1, Tab 81. ... Chaplin really meant was that Triventa had income against which to claim the expenses. [89]          Transcript, pg. 220, line 28 to pg. 221, line 20. [90]          Exhibit R-1, Tab 16. [91]          1997 CarswellNat 1768. [92]          2002 FCA 38. [93]          Ms. ...

Facts [10]     The Appellant called three witnesses. The first witness, Dr. ... A supplier is defined in section 123 as "the person making the supply", and a recipient is defined as: (a)         where consideration for the supply is payable under an agreement for the supply, the person who is liable under the agreement to pay that consideration, (b)         where paragraph (a) does not apply and consideration is payable for the supply, the person who is liable to pay that consideration, and (c)         where no consideration is payable for the supply,             [...] ... Group & Associates v. Wolfe (1998), 21 C.P.C. (4th) 366 (Ont. Gen. ...

Sherman   Firm: Legacy Tax & Trust Lawyers For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           2010 QCCQ 9283 ...   [4]           1976 31 C.C.C. (2d) (144) Ontario County Court.   [5]           (2001) 4 C.T.C. 2613.   ...

  [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. ...

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. ...

The Queen, 2007 TCC 717 (Informal Procedure)         Docket: 2007-2045(IT)I BETWEEN: MANON THERRIEN, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... Bella Lewkowicz, Translator           Citation: 2007TCC717 Date: 20071219 Docket: 2007-2045(IT)I BETWEEN: MANON THERRIEN, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ...   [9]      There are two paragraphs.  The second one reads as follows:             [TRANSLATION]...   ...

The second change in use occurred in 2008, when the appellants started to use the property again as a personal residence- triggering both a change of use pursuant to subparagraph 45(1)(a)(ii) of the Act, and a deemed disposition pursuant to paragraph 13(7)(a) of the Act. [31]         Under paragraph 13(7)(b) of the Act, the capital cost of the building, for the first change in use in 2007, is $411,075. determined as follows: 13(7)(b)(i) FMV of the property at the time of the change in use (2007) $695,000  x 78.3%=     $544,185         13(7)(b)(ii)(A) Cost of the property $355,000 x 78.3% =     $277,965 13(7)(b)(ii)(B) ½ x (FMV at the time of the change in use (2007) – (Cost of the property according to 13(7)(b)(ii)(A) + (2x Amount claimed as a capital gain deduction) ½ x (544,185 – (277,965+ (2 x 0)) = ½ x 266,220 =         $133,110         13(7)(b)(ii) The total of (A) and (B): 277,965 + 133,110 =     $411,075         13(7)(b) Capital cost of the building is the lesser of (i) and (ii) $544,185 or $411,075 $411,075 [32]         Therefore, pursuant to paragraph 13(7)(b) of the Act, the appellants are deemed to have acquired the building at the time of the change in use in 2007 for the amount of $411,075. [33]         With regards to the second change in use in 2008, paragraph 13(7)(a) of the Act deemed the appellants to have disposed of the property at that time for proceeds equal to its fair market value and to have reacquired it immediately thereafter at a cost equal to its fair market value, namely $510,000. ... Applying subsection 20(16) of the Act in this appeal, the terminal loss is $12,114.97 calculated as follows: A Capital cost of the building (As determined by 13(7)(b) of the Act) + Appraisal fee related to the building   $411,075 + ($ 472.50 x 78.3%= 369.97)         $411,444.97 B Recaptured depreciation included in the appellant’s income in previous years   $0 E Capital cost allowance deducted by the appellants   $0 F The lesser of:-           Proceeds of disposition-           Capital cost of the property 510,000 x 78,3% = $399,330 or $411,444.97       $399,330         20(16) A + B – E – F = Terminal loss according to 20(16) of the Act 411,444.97 + 0- 0- 399,330 =         $12,114.97 [35]         Mr. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

., 2007 TCC 459       Docket: 2006-2488(EI) BETWEEN: DESROBEC INC., Appellant, and   MINISTER OF NATIONAL REVENUE Respondent, and   JACQUES TURBIDE, Intervener.   ...     “ Réal Favreau ” Justice Favreau       Translation certified true on this 10th day of October 2007 Stefan Winfield, Translator       Citation: 2007TCC459 Date: 20070815 Docket: 2006-2488(EI) BETWEEN:   DESROBEC INC., Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent, and   JACQUES TURBIDE, Intervener.   ...   [34]    For these reasons, the appeal is dismissed.     Signed at Montréal, Quebec, this 15th day of August 2007.         ...

[OFFICIAL ENGLISH TRANSLATION]   REASONS FOR JUDGMENT   Jorré J.   Issues   [1]      The Appellant, Mr. ... Signed at Ottawa, Canada, this 24th day of July 2007.       “Gaston Jorré” Jorré J.     ... This conduct is unacceptable.         ...