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In Stewart v The Queen, [2002] 2 S.C.R. 645, the Court made the following comment: 57.      ... Smith DATE OF JUDGMENT: April 29, 2016   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Emmanuel Jilwan   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           Peter Hogg, Joanne Magee and Jinyon Li, Principles of Canadian Income Tax Law, 8th ed. ...

We would emphasize that this provision is applicable after June 17, 1999. [...] 26.        ... ·         Subsection 152(9) of the ITA [12]     Following the Supreme Court's decision in Continental Bank Leasing Corp. v. ... Canada, [2002] T.C.J. No. 641, at paragraphs 17 ff., Associate Chief Justice Bowman cites the concerns of a number of judges of this Court regarding the circumstances of the burden of proof where the Minister pleads assumptions of facts that were not known or were disregarded on assessing. ...

._______________________________________________________________ Appeal heard on October 23, 2002 at Montréal, Quebec Before: The Honourable Judge Alain Tardif Appearances: For the Appellant: The appellant himself Counsel for the Respondent: Jocelyne Mailloux Martin_______________________________________________________________ [OFFICIAL ENGLISH TRANSLATION] JUDGMENT The appeal from the assessment made under Part IX of the Excise Tax Act, notice of which is dated December 18, 2001 and which bears number PL2001-378, for the period from June 30, 1991 to December 31, 1999, is dismissed, with costs in favour of the respondent, in accordance with the attached Reasons for Judgment. ... "). [2]      The assumptions of fact on which the assessment being appealed from was based are as follows: (a)         The COMPANY was incorporated in 1984 under Quebec's Companies Act (R.S.Q., c. ... Since that assessment was not appealed from, it was confirmed and became final. [32]     It is important to recall that the appellant was the only director of the company, for all the years at issue. [33]     Can we ignore the existence of the two separate legal entities? ...

I.     INTRODUCTION [1]   This is an appeal by Mr. Darrell Brown (“Mr. ... Brown loaned an additional $91,746.78 to the Gallery. [29] V.       ANALYSIS 1.   ... Canada, 2002 SCC 46. [31] Ibid at para 50. [32] Stewart at para 50. [33] Ibid. [34] Ibid at para 52. [35] Ibid at para 60. [36] Ibid. [37] Ibid at para 55. [38] Ibid. [39] Stewart par. 54 [40] Ibid. [41] Ibid. [42] Moldowan v R, [1997] 1 S.C.R. 480. [43] Stewart at para 55. [44] Ibid at para 58. [45] Motech Moldings Inc. v. ...

        - Jordi Bonet- Hotel des Encans- 02/26/01- sculpture de         devant de cheminee (110 c 214 c 43 x 84) ceramic- $4000         - Joe Fafard- Masters- 06/13/01- Rae 38 x 15 cm- ceramic sculpture- $8000         - Heffel's- 11/07/96- cow- 56 x 33 cm- ceramic        sculpture- $7500         - Sotheby's- 11/15/95- Little Choc- 36 x 14 cm- painted     ceramic sculpture- $6000         - Vic Cicansky- 11/29/00- Couch Potatoes, 27 x 11 cm-       ceramic sculpture 1987- $900         - 10/24/94- VG- untitled, 45 x 49 cm- glazed ceramic-         $3000         - Claude Vermette 02/21/94 HE- untitled, 39 x 15 cm-            enamelled ceramic- $80         - Robert Roussil- 10/20/92 HE- Sans titre, 43 x 37 cm-         clay sculpture- $1100         - Emily Carr- 05/10/00- Thunderbird, 6 x 1 cm- painted        ceramic $1200         - 11/06/97- Thunderbird, frog, Bear- 3 ceramic sculptures-          $6000 47.     ... The Queen, 2000 DTC 1874 (affd) 2002 DTC 6874 and Klotz v. The Queen, 2004 T.C.C. 147. ... Paul Maréchal: Title:         Untitled (woman's head) Date:         1952 Medium:            Glazed ceramic Dimensions:       58 x 32 x 26 cm Appraisal:          $8,000 Louis Archambault (1915-) is a sculptor whose career spans some sixty years. ...

He has been retired since 1998. [9]      The appellant Serge Roberge is a lawyer by profession. ... Canada, [2002] S.C.J. No. 46, the Supreme Court of Canada considered the test of the reasonable expectation of profit; we need only reproduce here the Court's summary, found at paragraphs 60 and 61: 60.        ... As such, a source of income by definition exists, and there is no need to take the inquiry any further. 54.        ...

Before: The Honourable Judge Lucie Lamarre Appearances: Agent for the Appellant: Louis Leclair Counsel for the Respondent: Justine Malone____________________________________________________________________ JUDGMENT           The appeal from the assessment made under Part IX of the Excise Tax Act, notice of which is dated March 8, 2002, and bears number 18472, for the periods from October 1, 1998, to December 31, 1998, and from January 1, 1999, to February 13, 1999, is dismissed. ... Zalba's mismanagement of the restaurant and his bad faith. [13]      On November 5, 1998, Mr. ... Zalba. [...] [16]      Later correspondence, dated January 29, 1999, shows that Mr. ...

The Queen, 2021 TCC 58 Docket: 2017-4032(IT)G BETWEEN: MICHAEL KALLIS, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... (a) Assistive Financial Corporation (“AFC”) [13] AFC was a private corporation incorporated in 2002 [9] and its capital came from debt financed from the issuance of unsecured notes and debentures. [10] Its main business activity was raising capital and financing loans administered by The Cash Store Financial Services Inc. ... “Susan Wong” Wong J.   CITATION: 2021 TCC 58 COURT FILE NO.: 2017-4032(IT)G STYLE OF CAUSE: MICHAEL KALLIS v. ...

This enhances safety by decreasing the risk of local anesthetic toxicity.   ... The epinephrine is not essential. [23]   Mr. Eric Ormsby, a retired public servant employed by Health Canada as Manager, Office of Science, Bureau of Policy, Service and International Programs, Therapeutic Products Directorate, Health Products and Food Branch, since October 2002, testified at the hearing at the request of the respondent. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Tax Convention (the "Treaty") by the 15 th day of the month following the month of payment [paragraph 1]. [10]       By Non-Resident Notice of Assessment No. 6200958 (the "1998 Assessment") dated December 12, 2002, the Minister of National Revenue (the "Minister") assessed the Appellant for its taxation year ended December 31, 1998 for non-resident tax of $7,871.76 (the "1998 Assessment Amount") [paragraph 1]. [11]       The 1998 Assessment also included "Failure to Deduct" penalties of $787.17 and interest of $3,491.60 [paragraph 1]. [12]       In arriving at the 1998 Assessment Amount, the Minister took the position that the One-Time License Fee was a "rent, royalty or similar amount" and therefore subject to a 10% withholding tax pursuant to paragraph 212(1)(d) and subsection 215(1) of the Act and Article XII of the Treaty [paragraph 1].... [3]      The following facts were also established: 6.          ... Tab 2, Schedule 1, para. 21 Exhibit 2, Exhibit B-6 & B-10 25.        ... Saint John Shipbuilding & Dry Dock Co. Ltd. 80 D.T.C. 6272(FCA) @ 6274 31.        ...