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(the “Act”) in relation to his 2008 taxation year and a related request for loss carryback to the 2005, 2006 and 2007 taxation years. ... These business losses, if allowed, would result in the refund to the Appellant of all the taxes paid or deducted at source for the 2005, 2006, 2007 and 2008 taxation years. ... The Queen, 2005 TCC 545; Panini v. Canada, 2006 FCA 224; Laplante v. The Queen, 2008 TCC 335; Gélinas v. ...

Giles--------------   Allwest Reporting Ltd. #1200- 1125 Howe Street Vancouver, B.C. ... Moore, the period covered is December 1 st, 2004 to September 28 th, 2005.  ... Moore are allowed only to the extent that the period from September 1 st, 2005 to September 28, 2005 was worked as an employee rather than an independent contractor.  ...

The applicant filed her claim for refugee protection on March 16, 2016. [4]   The RPD held a hearing in March 2017. ... However, I also agree that it was not unreasonable to consider the applicant’s actions, including her annual trips to the United States and Canada between 2005 and 2010, and the fact that she did not file her claim for refugee protection immediately after her most recent arrival in Canada. ... The RAD reasonably concluded – based on these factors, as well as the delay in filing the claim, her return to Haiti and the fact that she had articulated her lack of fear spontaneously and repeatedly during the hearing – that the applicant did not have any subjective fear of persecution if she returned to Haiti. [15]   There is therefore no need to intervene in this case. ...

Johnson was interviewed by the police in 2005. She testified that it was only at this point that she began to have doubts about the trustworthiness of Mr. ... Partnership, 2005 ABQB 637; Den Haag Capital, LLC v. Correia, 2010 ONSC 5339). ... Canada, 2005 FCA 252. Mr. Hammill was induced to purchase gems for eventual resale, and accumulated a significant inventory. ...

Canada (National Revenue), 2011 FC 166   Federal Court   Cour fédérale Date: 20110211 Docket: T-338-10 Citation: 2011 FC 166 Ottawa, Ontario, February 11, 2011 PRESENT:     The Honourable Madam Justice Simpson     BETWEEN:   DAVID BURKES       Applicant   and       THE MINISTER OF NATIONAL REVENUE         Respondent                    REASONS FOR JUDGMENT AND JUDGMENT   [1]                Pursuant to section 18.1 of the Federal Courts Act, RSC 1985, c F-7, Mr. ...   [5]                However, in spite of his medical problems, the Applicant earned the following gross professional income: in 2004, $478,400, in 2005, $542,830, in 2006, $549,400, in 2007, $635,655 and in 2008, $633,775 ... Kirvan Deputy Attorney General of Canada Toronto, Ontario FOR THE RESPONDENT                       ...

The Queen, 2022 TCC 60 Docket: 2019-4229(GST)G BETWEEN: CFI FUNDING TRUST, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Hogan” Hogan J.   Citation: 2022 TCC 60 Date: 20220609 Docket: 2019-4229(GST)G BETWEEN: CFI FUNDING TRUST, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Bass Angelo Gentile Firm: Aird & Berlis LLP Brookfield Place 181 Bay Street, Suite 1800 Toronto, Ontario M5J 2T9 For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   [1] RSC 1985, c E-15. [2] SOR/91-45. [3] Westborough Place Inc v R, 2007 TCC 155. [4] International Hi‑Tech Industries Inc v R, 2018 TCC 240. [5] Vocan Health Assessors Inc v R, 2021 TCC 49. [6] 1378055 Ontario Limited v R, 2019 TCC 149. [7] Westborough Place Inc, supra note 3. [8] International Hi‑Tech Industries Inc, supra note 4 at para 65; Vocan Health Assessors Inc, supra note 5 at para 177; and 1378055 Ontario Limited, supra note 6 at para 53. [9] David Sherman, “169(4) Input Tax Credits – Required Documentation” (last modified 30 April 2022), online: Taxnet Pro. [10] Canada Revenue Agency, “May 2004 CRA Roundtable” (January/February 2005 member advisory), online (pdf): Chartered Professional Accountants of Alberta. [11] David Sherman, supra note 9. [12] Ruth Sullivan, Statutory Interpretation, 3rd ed (Toronto: Irwin Law, 2016) at 79. [13] Ibid at 80. [14] Canada Trustco Mortgage Co v R, 2005 SCC 54 at para 10. [15] All of the MCLAs are substantially similar. ...

The Queen, 2005 TCC 635, aff’d 2006 FCA 177, 60 D.T.C. 6358). [12] In 2004, a group of the impacted taxpayers, which did not include Mr. ... RIVOALEN J.A.   DATED: august 19, 2022   APPEARANCES: J. Randall Barrs   For The Appellant   Andrea Jackett For The Respondents SOLICITORS OF RECORD: J. Randall Barrs Toronto, Ontario   For The Appellant   A. François Daigle Deputy Attorney General of Canada For The Respondents     ...

New Brunswick, [2008] 1 S.C.R. 190, 2008 SCC 9, at para. 51 (" Dunsmuir "). ... Canada (Customs and Revenue Agency), 2005 DTC 5245, 2005 FCA 153, that unreasonableness simpliciter (one of the two deferential standards then applied by the courts) was the standard of review applicable to a decision made under subsection 220(3.1). [32] Issues of procedural fairness are reviewable on the standard of correctness; see the decision in Canada (Citizenship and Immigration) v. ... That test is as follows: [W]hat would an informed person, viewing the matter realistically and practically – and having thought the matter through – conclude. ...

Accordingly, the date of payment could simply not have been June 10, 1995 for the purposes of crediting the Overpayment to the taxpayer’s 1993 tax liability. [11]         I frankly do not agree with the Appellant’s interpretation of the plain meaning of subsection 187(2) and find no ambiguity in the interpretation of same; however even if I agree that the Appellant’s position creates an ambiguity in interpretation, I could not find in the Appellant’s favour based on a textual, contextual and purposeful approach to interpretation for several of the reasons the Respondent has well argued. [12]         Both parties relied on the Supreme Court of Canada’s decision in Canada Trustco Mortgage Co v Canada, [2005] 2 SCR 601, 2005 SCC 54 for the principles of statutory interpretation found at paragraph 10:    It has been long 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”: see 65302 British Columbia Ltd. v. ... Pizzitelli DATE OF JUDGMENT: February 12, 2015   APPEARANCES:   Counsel for the Appellant: Matthew G. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

(ii)       He did not know the other associates of the partnership. (iii)      He did not participate in any associates meetings. ... Papion [13]     In December 2005, Claude Papion, a computer expert, was mandated by the Respondent to carry out an assessment of the requests regarding the partnership's scientific research activities using the documentation submitted by the partnership and the documentation related to the assessment of admissibility of the partnership's prior research work, carried out by Georges Husson, external scientific reviser who had done work for Revenue Canada. ... This report dated January 17, 2005, was submitted as evidence by the Respondent (Exhibit I-1). ...