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Spiro” Spiro J.   Docket: 2019-4446(IT)G BETWEEN: REBECCA FORD, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Spiro” Spiro J.   Table of Contents   TOC \o "1-3" \h \z \u I. ... Definitions 108(1) In this Subdivision, trust  includes an inter vivos trust and a testamentary trust but […] does not include (a) … an employee benefit plan …                                                                                                                                             CITATION: 2024 TCC 96 COURT FILE NO.: 2019-4444(IT)G, 2019-4445(IT)G, 2019‑4446(IT)G and 2019-4447(IT)G STYLE OF CAUSE: RONALD KARY BLACK AND HIS MAJESTY THE KING MURPHY PETTYPIECE AND HIS MAJESTY THE KING REBECCA FORD AND HIS MAJESTY THE KING JASON MURPHY AND HIS MAJESTY THE KING PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: September 18, 19 and 20, 2023 and February 8 and 9, 2024 REASONS FOR JUDGMENT BY: The Honourable Justice David E. ...

The Queen, 2008 TCC 84         Docket: 2006-1125(IT)G BETWEEN: MICHAEL R. ...     “ Campbell J. Miller” Miller J.         Citation: 2008TCC84 Date: 20080206 Docket: 2006-1125(IT)G BETWEEN: MICHAEL R. ... Seymour withdrew amounts from the Companies in 1999 and 2000, which were allocated and debited to their respective shareholder loan accounts in draft financial statements prepared in the fall of 2002.   ...

The Queen, 2007 TCC 474 (Informal Procedure)         Docket: 2007-355(IT)I BETWEEN: C. ... Webb” Webb J.           Citation: 2007TCC474 Date: 20070815 Docket: 2007-355(IT)I BETWEEN: C. ...   [11]  In Cavalier v. R., 2001 CarswellNat 2374, [2002] 1 C.T.C. 2001, Justice Bowie made the following comments on the Thomson case:   One thing is clear from Thomson, however; the meaning of the expression ordinarily resident is far from certain ...

For the purposes of this appeal, I am left to decide the deductibility of the following expenses:            (1)       RBC                                              $13,070,777.00            (2)      Simmons                                          $5,171,164.00            (3)       GLCC- (a) hello fees of                 $6,900.000.00                                      (b) break fees of             $23,601.591.00 [4]      BJ Services Company Canada v. R., [2002] G.S.T.C. 124 (T.C.C.), the companion case to the present one, decided by Justice Miller, dealt with the application of the goods and services tax and the eligibility for input tax credits for the legal and financial advisory fees of Blake, RBC and Simmons. ... R., 2002 DTC 2185 (T.C.C.). The two latter cases dealt with the deduction of professional advisory fees incurred in takeover bids. ...

Weisman" Weisman D.J.         Citation: 2009 TCC 198 Date: 20090421   Docket: 2008-1378(CPP) BETWEEN: TORONTO TRANSIT COMMISSION,   Appellant, and   THE MINISTER OF NATIONAL REVENUE,   Respondent.   ... Signed at Toronto, Ontario, this 21st day of April 2009.         "N. ... No. 901 (TCC) [11] [2002] F.C.J. No. 660 (F.C.A.) [12] [2003] F.C.J. No.862 (F.C.A.) ...

Signed at Ottawa, Canada this 20 th day of August, 2007.   "T. O'Connor" O'Connor, J.         ...     [8]     Christina is Bruce’s wife.   [9]     Choi was a resident of Korea during the Period ... Canada, [2002] F.C.J. No. 771 (F.C.A.), where Sexton J.A., said the question to be answered with respect to this test is “is the person who has engaged himself to perform the services performing them as a person in business on his own account”. ...

("Zuniq") (we are talking more than 500 taxpayers involved here). [6]      On October 22, 2002, following a decision by this Court in McKeown, supra, unfavourable to the investors, counsel for the Appellant stopped representing her, and the Appellant, wanting to pursue her appeal, ultimately went ahead with a hearing in September 2005. ... 4.      Did the process result in a technological advancement? 5.      ... Chamberlain, Revisor CITATION:                                        2005TCC666 COURT DOCKET NO.:                     98-3791(IT)I STYLE OF CAUSE:                           Lucette Carpentier and Her Majesty the Queen PLACE OF HEARING:                      Ottawa, Ontario DATES OF HEARING:                      September 19, 20, 21, 23 and 28, 2005 REASONS FOR JUDGMENT BY:     The Honourable Justice Lucie Lamarre DATE OF JUDGMENT:                     October 26, 2005 APPEARANCES: For the Appellant: The Appellant herself For the Respondent: Pierre Cossette and Philippe Dupuis COUNSEL OF RECORD:        For the Appellant:                    Name:                                                 Firm:        For the Respondent:                     John H. ...

Signed at Ottawa, Canada, this 9th day of February 2010.       "Paul Bédard" Bédard J.             ... Ruest, who claims that the market conditions in 2002, 2004 and even 2005 were the same as in 1999. ...

Rip" Rip, J.     Translation certified true on this 26 th day of April 2004.           ... Canada, [2002] T.C.J. No. 176, Bowman J. is of the opinion that if it is possible that the taxpayer wrongly trusted his accountant and that the assumption is plausible, the Court must give him the benefit of the doubt:   Reverting to the case of the penalty imposed under section 285 against the appellant there is much merit in Mr.  ...

  (2)  No evidence is admissible on an application,               (a)        under paragraph (1)(a), except with leave of the Court or on consent of the parties, or               (b)        under paragraph (1)(b) ... R., 2002 DTC 1264, a similar motion by the Appellant, was made before the Examination for Discovery of the Respondent's witness and the Respondent's subsequent undertakings. ...   [16]     Therefore the application is dismissed.   Signed at Edmonton, Alberta, this 17th day of October 2003.     ...