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As stated by the Supreme Court of Canada in Canada Trustco Mortgage Co. v R, 2005 SCC 54, [2005] 2 SCR 601 at paragraph 10: It has long been established as a matter of statutory interpretation that “the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”…The interpretation of a statutory provision must be made according to a textual, contextual and purposive analysis to find a meaning that is harmonious with the Act as a whole. ... Subsection 55(2) opens with the words “ a corporation ” and subsequently in paragraph (a) states “ shall be deemed not to be a dividend received by the corporation ”. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Wilhelm   JUDGMENT   The appeal with respect to the 2009 taxation year is dismissed.     ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601, at paragraph 26, elaborated that the term should be “read not in the sense of actual knowledge but in the broader sense of ‘because of’ or ‘in relation to’ the series” (this interpretation was confirmed in Copthorne, paragraphs 55-56). ... Wilhelm   COUNSEL OF RECORD: For the Appellant: Name: Alan Louie   Firm:   For the Respondent: Nathalie G. ...

Justice Shore   BETWEEN:   GLADIS EUGENIA TABARES SALDARRIAGA NICOLE MARAVILLA       Applicant   and       THE MINISTER OF CITIZENSHIP AND IMMIGRATION         Respondent     REASONS FOR ORDER AND ORDER   I.   ... On April 13, 2005, I gave birth to my daughter, Nicole Maravilla, an American citizen. ... Montréal, Quebec FOR THE APPLICANT     MYLES J. KIRVAN Deputy Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT                 ...

.____________________________________________________________________ Appeal heard on April 26 and 27, 2005, at Charlottetown, Prince Edward Island, By: The Honourable Justice A.A. ... A.         Yeah. Q.         Now, you didn't do that, did you? A.         ... Coady and Her Majesty the Queen PLACE OF HEARING: Charlottetown, Prince Edward Island DATE OF HEARING: April 26 and 27, 2005 REASONS FOR JUDGMENT BY: The Honourable Justice A.A. ...

RENNIE J.A.   BETWEEN:     CANADIAN IMPERIAL BANK OF COMMERCE     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard by online video conference hosted by the registry on February 16, 2021. ... RENNIE J.A.   BETWEEN:     CANADIAN IMPERIAL BANK OF COMMERCE     Appellant     and     HER MAJESTY THE QUEEN     Respondent   PUBLIC REASONS FOR JUDGMENT WEBB J.A. [1] The Canadian Imperial Bank of Commerce (CIBC) made substantial payments to Aeroplan Limited Partnership (Aeroplan) under the agreement between these companies related to the Aeroplan credit cards issued by CIBC. ... Canada, 2005 FCA 252, 257 D.L.R. (4th) 1, noted: [31] In an appeal against an assessment under the Act, the outcome does not belong to the parties. ...

Canada (Attorney General), 2005 SCC 25, [2005] 1 S.C.R. 401, at paras. 55-56 and 69-70; Salomon v. ... A fair reading of his reasons reflects the focus on the allocation of the income of AIGLP and the losses of the GERI partnership. [50] The only partners of the GERI partnership, as set out in paragraph 99 of the Partial Agreed Statement of Facts and Schedule “A” to that agreement, were: ● Elisa Aquilini ● Francesco Aquilini ● Roberto Aquilini ● Paolo Aquilini ● Global Coin Corporation ● Cranberry Plantation Inc. [51] None of the EAFT, the FAFT, the RAFT, or the PAFT were partners of the GERI partnership. ... François Daigle Deputy Attorney General of Canada For The Respondent   ...

DAWSON D.J.C.A.   BETWEEN:     HIS MAJESTY THE KING     Appellant/ Respondent on cross-appeal     and     VEFGHI HOLDING CORPORATION and S.O.N.S. ENVIRONMENTAL LTD.     Respondents/ Appellants on cross-appeal   Heard at Vancouver, British Columbia, on March 4, 2025. ... DAWSON D.J.C.A.   BETWEEN:     HIS MAJESTY THE KING     Appellant/ Respondent on cross-appeal     and     VEFGHI HOLDING CORPORATION and S.O.N.S. ...

Under section 163(2) of the Income Tax Act, RSC 1985, c.1, as amended the (“ ITA ”) and under section 285 of the Excise Tax Act, RSC 1985, c.E-15, as amended (the “ ETA ”), penalties were also imposed. ... McDougall, 2008 SCC 53 (“ McDougall ”) and Merck Frosst Canada Ltd. v. ... Canada, 2005 FCA 104 at paragraphs 34 – 35. [40] Income Tax Act, RSC 1985, c 1 (5th Supp), s 152(4)(a)(i) [ITA]. [41] Naguib v. ...

Signed at Ottawa, Canada this 1st day of September, 2009.         “G. ... Canada, [2005] T.C.J. No. 266.   [2] Exhibit A-1. [3] Exhibit A-2. ...

THE ESTATE OF PASQUALE PALETTA     PLACE OF HEARING: TORONTO, ONTARIO   DATE OF HEARING: APRIL 4, 2022   REASONS FOR JUDGMENT BY: NOËL C.J.   ... LASKIN J.A.   DATED: May 17, 2022   APPEARANCES: Justice Malone Dina Elleithy   For The Appellant   Justin Kutyan Kelly Ng   For The Respondent   SOLICITORS OF RECORD: A. François Daigle Deputy Attorney General of Canada Ottawa, Ontario   For The Appellant   KPMG Law LLP Barristers and Solicitors Toronto, Ontario For The Respondent     ...