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In 2019, I opened a Bank of Montreal (“ BMO ”) account as a non-resident of Canada for tax purposes. […]. 16. The BMO Account has been garnished by the Canada Revenue Agency (“ CRA ”) since 2022 in the amount of $4,637.82 CAD. […] 22. ... See also, Morissette c Canada, 2019 CCI 103, Satinder v Canada, 2002 FCA 491, Ludmer v Canada, 1994 CanLII 3547 (FCA), Kennedy v Canada, [2001] TCJ No 486, Estate of Dora Greenstone v The Minister of National Revenue, 91 DTC 969 and Canada (Canadian Human Rights Commission) v Canada (Attorney General), 2011 SCC 53. [14] Moulton v The Queen, 2002 CanLII 798 at para 11 (TCC) [Moulton]. ...

The Queen, 2015 DTC 1106, 2015 TCC 73           Docket: 2013-1264(IT)G BETWEEN: CAROLINE M. ... Chapman, who died in 2011, was assessed income tax for 1999, 2000 and 2001 by notices of assessment dated April 7, 2005 and for 2002 on November 1 st, 2004. [3]              Ms.  ...   [7]           [2003] F.C.J. No. 1693 (QL), 2003 FCA 423. [8]           [2009] T.C.J. ...

Medical expenses – lawn care, personal grooming and housekeeping.   [3]              Ms. ... Until 2002, her mother was able to look after this for her, but in recent years she has had to hire someone to make the necessary alterations. ...   [2]           2007 TCC 388.   [3]           1996 CarswellNat 1521, [1996] 3 C.T.C. 2178.   ...

In so reassessing the Appellant for the 1998 and 1999 taxation years, the Minister relied on the following assumptions of fact:             (a)         those admitted to and stated above; (b)          the Appellant allegedly started Ptarmigan Adventures in May of 1995, in order to offer snowmobile tours, (the "Activity") during the time period of December 25 th to April 30 th each year; (c)          the alleged Activity was to provide guided tours of the Labrador coast by snowmobile, and was to include the use of cabins owned by the Appellant; (d)          the Activity has generated no sales or revenues of any kind since its alleged start-up in 1995; (e)          the Appellant has not provided any tours since 1995; (f)           the activity has reported losses since 1995 detailed as follows:                                                 Sales                 Loss              1995                            Nil                     ($12,350)              1996                            Nil                        (5,481)              1997                            Not reported     Not reported              1998                            Nil                        (8,072)              1999                            Nil                        (6,840) (g)          the Appellant claimed the losses as outlined above on his tax returns for those years; (h)          the Appellant owned one snowmobile prior to 1995; (i)           the Appellant owned 3 cabins for at least 10 years prior to 1995; (j)           the cabins were approximately 80 km from the Appellant's residence; (k)          the cabins remained vacant and unused for at least the last 10 years prior to 1995; (l)           the Appellant began claiming expenses including CCA in relation to his cabins and snowmobile in 1995; (m)         the Appellant recorded the cabins on a CCA schedule at an amount of $17,200; (n)          the Appellant has claimed CCA on the cabins, and as at December 31, 1999 the Undepreciated Capital Cost of the cabins had been reduced to $12,845.77; (o)          the Appellant did not earn any revenue from the cabins at any time since 1995; (p)          the Appellant made no effort to earn any revenue from the cabins; (q)          the Appellant drove a snowmobile for approximately 25 years, including the years at issue, for personal use; (r)           the use of the snowmobile earned no revenue since 1995; (s)          there was sufficient snowfall during the years at issue for driving a snowmobile; (t)           at all relevant times the Appellant operated an ambulance business and was on call 75% of the time; (u)          during the times the Appellant worked at his ambulance business, he was unavailable to work in the activity; (v)          the Appellant did not maintain sufficient books and records to calculate his income tax liability; (w)         the activity was not run in a business like manner; (x)          the activity was a personal endeavor of the Appellant and not carried out in the pursuit of profit; (y)          the expenses claimed by the Appellant were not incurred for the purpose of earning income from a business or property; and (z)          the Appellant did not have a reasonable expectation of profit during the relevant taxation years. [3]      The Appellant and Mr. ... [Transcript at page 22, line 24 to page 23, line 3]. [....]             ... Canada, [2002] S.C.J. No. 46, at paragraph 50, set out the following test in broad terms: (i) Is the activity of the taxpayer undertaken in pursuit of profit, or is it a personal endeavour? ...

The Queen, 2016 TCC 246 Docket: 2012-4380(IT)G BETWEEN: CHARMANE TOMLINSON, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... REASONS FOR JUDGMENT   Bocock J. I. Introduction [1]              Ms. ... Jarvis, 2002 SCC 73 highlighted the obligations of taxpayers and well as the provision to ensure taxpayers feel so obliged to comply: 49        Every person resident in Canada during a given taxation year is obligated to pay tax on his or her taxable income, as computed under rules prescribed by the Act (ITA, s. 2 …). ...

  [13]         The initial hypothesis on which the project was based, as Mr.  ... The Queen, 2001 FCA 393, [2002] 1 C.T.C. 212, at paragraph 17, as follows: 1.         ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Signed at Ottawa, Canada, this 10th day of July 2007.     "Diane Campbell" Campbell J.         ... The Queen, 2002 DTC 6853, and although the Court’s analysis was based on the Articles of the Civil Code of Quebec, it referenced the principles in Sagaz Industries. ... Signed at Ottawa, Canada, this 10th day of July 2007.         "Diane Campbell" Campbell J.       ...

Turcotte inc.           In all other respects, the Minister's assessment is upheld.           ... He established the percentage of personal use at 20% of the total use of the trailer during his examination for discovery, an examination that was included in the record of the evidence for this case with the parties' consent. e) The appellant retired in 2002, and since that time, he has been using the trailer for personal purposes. [34]     With regard to all of the evidence, I have come to the conclusion that the trailer was used primarily for the purposes of the appellant's business during the years at issue. ... Certified true translation Colette Beaulne REFERENCE:                                    2004TCC597 COURT DOCKET NO.:                     2001-4222(GST)G STYLE OF CAUSE:                           Claude Paquin and Her Majesty the Queen PLACE OF HEARING:                      Nicolet, Quebec DATE OF HEARING:                        May 18, 2004 REASONS FOR JUDGMENT BY:     The Honourable Chief Judge Alban Garon DATE OF JUDGMENT:                     September 2, 2004 APPEARANCES: For the Appellant:                      Jacques Renaud For the Respondent:                  Robert Poupart COUNSEL OF RECORD: For the Appellant:                    Name:                    Jacques Renaud                    Firm:            Renaud Brodeur                                                 Montreal, Quebec For the Respondent:                  Morris Rosenberg                                                 Deputy Attorney General of Canada                                                 Ottawa, Canada [1] In the evidence, Construction Milette inc. is mentioned; this is the same company as Construction D.M.B. s.e.n.c., and I will refer in these Reasons to Construction D.M.B. s.e.n.c. ...

A.       FACTS [1]      The Appellant is the Facilities Manager for the Christian Life Assembly (the "Assembly"). [2]      The Assembly is a Pentecostal church located in Langley, British Columbia. [3]      The Appellant is not an ordained Minister. [4]      In his capacity as a Facilities Manager the Appellant is responsible for the day-to-day administration of the Assembly. The Appellant supervises 21 paid employees and 17 volunteer workers at the Assembly. [5]      When the Appellant filed his income tax return for the 2001 taxation year he claimed a deduction in the amount of $10,800.00 as a clergy residence deduction (the "Clergy Deduction"). [6]      After the Minister of National Revenue (the "Minister") issued the original Notice of Assessment for the Appellant's 2001 taxation year, to allow the Clergy Deduction, the Appellant requested that the Minister allow an additional deduction in the amount of $1,441.00 for the utilities costs paid by the Appellant in the year. [7]      On the 2nd day of December 2002 the Minister reassessed the Appellant's 2001 taxation year and denied the Clergy Deduction claimed by the Appellant. ... C.       ANALYSIS [9]      Paragraph 8(1)(c) of the Income Tax Act (the " Act ") reads as follows: 8. (1)     In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:... ...

Canada, [2002] 3 CTC 2304, Justice Lamarre (as she then was) explained (at paragraph 14): To satisfy the definition of “eligible individual”, a taxpayer must meet two cumulative conditions: namely residing with the qualified dependent and primarily fulfilling the responsibility for the care and upbringing of the qualified dependent. [43]         The Minister referred to the recent decision of Jhanjii v. ... Smith DATE OF JUDGMENT: March 22, 2016   APPEARANCES:   Agents for the Appellant: Michael Ding Osnat Nemetz Counsel for the Respondent: Sebastian Budd Laurent Bartleman   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...