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RENNIE J.A.   BETWEEN:     GORDON RONALD GREGG, DONALD RICHARD MACDONALD, GLENN SORKO, FRANK COATES, NANETTE JOZWIAK, WILLIAM HANNA (IN THE CAPACITY OF ADMINISTRATOR OF THE ESTATE OF DONALD LLOYD GERKE), FREDERICK MARK HANLEY, DAVID BAXTER, CHRISTOPHER CHARLES JOHNSTON, JAMES ARTHUR BRADLEY, BRIAN LEONARD SOWTEN, WILLIAM CHARLES SCHULTZ, RUSSELL IRVING COOPER, WILLIAM ALEXANDER HACKWELL, NOEL MARTIN LOURENS, ALEXANDER GEORGE WILLIAM HEMINGWAY, FRANÇOIS RAUSCHER and LARRY CROWLEY     Appellants     and     AIR CANADA PILOTS ASSOCIATION and AIR CANADA     Respondents   Heard at Ottawa, Ontario, on March 14, 2019. ... In Vilven, meanwhile, the Federal Court (per Mactavish J.) concluded that a determination by the Canadian Human Rights Tribunal that age 60 was the “normal age of retirement” for domestic pilots from 2003 to 2005 was reasonable. ... The appellants failed to do so beyond the assertion that “[p]ilot employment within the Canadian airline industry has been quite volatile since 2005.” [9]   For their part, the appellants submit that insofar as any such evidence exists it lies in the hands of the respondent, Air Canada, which Air Canada could be compelled to provide before the Tribunal under its subpoena powers. ...

Human Resources, 2005 TCC 498 at paragraphs 3 and 6. [15]          Factually, the documentation provides a full answer to Mr. ... Bocock DATE OF JUDGMENT: October 24, 2017   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Emmanuel Jilwan   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

The Court heard the appeals together on common evidence. [2]              The Appellant reported a loss from a business on his income tax return for each of the relevant years, as follows:-          2008 taxation year: loss of $946,479-          2009 taxation year: loss of $16,537-          2010 taxation year: loss of $222,198-          2011 taxation year: loss of $268,916 [3]              For the 2008 taxation year, the purported business loss is shown on a form included as part of the Appellant’s 2008 tax return that is titled Statement of Agent Activities (the “ Statement of Agent Activities ”). ... Specifically, it was requested that $922,600 of the business loss reported on his 2008 income tax return be carried back and applied against his 2005, 2006 and 2007 taxation years. [6]              Through a number of assessments and reassessments, the Minister denied all of the business losses claimed by the Appellant. ...   [39]         I will first consider whether the Appellant made the false statements under circumstances amounting to gross negligence. [40]         The phrase “ gross negligence ” as used in subsection 163(2) was considered in the widely adopted decision of Venne v. ...

Bonner Appearances: Agent for the Appellant: Fareed Raza Counsel for the Respondent: Pavanjit Mahil____________________________________________________________________ JUDGMENT           The appeal from the assessment made under Part IX of the Excise Tax Act, notice of which is dated February 18, 2005 and bears number 11GU-GL040771539237 is dismissed, with costs, for the reasons set out in the attached Reasons for Judgment. ... Jong Sang Mo ("Mo");           2.        Roland Blanchette ("Blanchette");           3.        Shenaz Dharamshi ("Dharamshi");           4.        Parvaneh Beheshti ("Beheshti"); and           5.        ...

" S.J. Savoie " Savoie D.J. Translation certified true on this 29 th day of March 2005. ... ".    If the answer to that question is "yes", then the contract is a contract for services.    ... " S.J. Savoie " Savoie D.J. Translation certified true on this 24 th day of March 2005. ...

He grounds his argument on a number of passages from R v Henry, 2005 SCC 76, [2005] 3 S.C.R. 609, where the Supreme Court asserts that section 13 affords a protection against the use of prior testimony for “any purpose” (para 49). ... Campbell.   JUDGMENT in T-1618-17 THIS COURT’S JUDGMENT is that: 1.   ... Barristers and Solicitors Montréal, Quebec   For The Applicant   Attorney General of Canada   FOR THE RESPONDENT     ...

" Second, the definition of "contributed surplus" that is currently in the Handbook and to which Professor Thornton referred is quite different from the definition that was operative during the relevant taxation years. [48]     I have reproduced below the relevant excerpts from the Handbook during both periods, the period encompassing the taxation years at issue (1996-2000) and the period since the Handbook was changed (2005- present). ... Handbook (2005- present) Contributed surplus comprises amounts paid in by equityholders. ... Bornstein COUNSEL OF RECORD:        For the Appellant:                    Name:                              Jacques Bernier                    Firm:                                Bennett Jones LLP                                                           Toronto, Ontario        For the Respondent:                     John H. ...

In 2005, he started his company and did business under the name “Entreprises Darik”. ... He worked for Entreprises Darik from 2005 to 2009 and for 7547978 Canada Inc. in 2011 as a self-employed worker. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Translation certified true on this 5 th day of January 2005. Colette Dupuis-Beaulne, Translator Citation: 2004TCC447 Date: 20040716 Docket: 2002-4465(EI) BETWEEN: ALEXANDRE SYRIANNIS, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and GEORGES KUGIEL, Intervener. ... degree of control over the work or the worker;           2.        ownership of tools;           3.        ... Translation certified true on this 5 th day of January 2005. Colette Dupuis-Beaulne, Translator CITATION: 2004TCC447 COURT FILE No.: 2002-4465(EI) STYLE OF CAUSE: Alexandre Syriannis and M.N.R. and Georges Kugiel PLACE OF HEARING: Montréal, Quebec DATE OF HEARING: March 22, 2004 REASONS FOR JUDGMENT BY: The Honourable S.J. ...

ANALYSIS [9]              The relevant provision in this motion is section 53 of the Tax Court of Canada Rules (General Procedure) (the “ Rules ”), in particular subsection 53(1), of the Rules, which states: 53. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           2013 TCC 383 [Gramiak], upheld by 2015 FCA 40. [2]           General Motors of Canada Ltd v R, 2006 TCC 184, 2006 GTC 233, at para 21 [General Motors], citing Justice Bonner in Morris v Canada, 93 DTC 316, at page 317. [3]           Ibid. [4]           Niagara Helicopters Ltd v Canada, 2003 TCC 4, 2003 DTC 513. [5]           Holm v Canada, [2003] DTC 755, [2002] TCJ No 641 [Holm]. [6]           Holm, at para 9. Justice Bowman’s comments in Holm were quoted and approved by Justice Létourneau of the Federal Court of Appeal in Anchor Pointe Energy Ltd v Canada, 2007 FCA 188, at para 27. [7]           Mungovan v Canada, 2001 TCC 568, [2001] 3 CTC 2779 [Mungovan]. [8]               Mungovan, at para 10. [9]           Simard v R, 2015 TCC 2, 2015 CarswellNat 8, at paras 12 and 15 [Simard]. [10]          2005 TCC 250, [2005] 2 CTC 2772, aff’d by 2006 FCA 73. ...