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Translation certified true on this 26 th day of January 2005. Colette Dupuis-Beaulne, Translator Citation: 2004TCC593 Date: 20041015 Docket: 2003-4470(IT)I BETWEEN: GILLES BÉGIN, Appellant, and HER MAJESTY THE QUEEN, Respondent. [OFFICIAL ENGLISH TRANSLATION] REASONS FOR JUDGMENT Archambault J. [1]      Mr. ... Bégin provides this explanation: [TRANSLATION] [...] During an attack of cataplexy: (1)         Vision becomes blurred and eyelids drop, eyes roll back. (2)         Walking requires holding on before bending and standing still. (3)         Speech is illogical even though senses remain active... language remains irrational. (4)         Mental faculties (perceiving, thinking and remembering) are seriously affected by this decrease in alertness and concentration. [18]     I therefore conclude that, although Mr. ...

The Appellant submits that non-capital losses incurred in 661’s 2001 and 2002 taxation years were carried back or ought to have been thereby reducing 661’s taxable income for its 2000 taxation year. [9]   The Minister reassessed 661’s taxation year ending on October 31, 2000 on the following dates: •   August 13, 2001 (initial assessment); •   April 24, 2002 (application of loss carry-back from 2001); •   October 23, 2003 (application of loss carry-back from 2002); •   January 14, 2005 (adjustments and overall decrease to loss carry‑back from 2001 as a result of the Grosvenor settlement); and •   November 20, 2008 (application of the loss carry-back from 2003). ... A.   Have I read it?   No. Q.   Are you aware of it? A.   Yes. Q.   You're aware of this requirement? ... A.   Yes. Q.   Yes?   And what does that mean?   What is your understanding of that policy? ...

The Queen, 2013 DTC 1018 [at at 93], 2012 TCC 406, rev'd supra         Citation: 2012 TCC 406 Date: 2012 1214 Docket: 2010-1429(IT)G   BETWEEN: ALLEN BERG, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       ...   [29]       In Webb v. R., 2004 TCC 619, [2005] 3 C.T.C. 2068 (T.C.C. ... Pentney                                                           Deputy Attorney General of Canada                                                           Ottawa, Canada [1]  92 DTC 6031 (F.C.A.) [2] [1997] 2 C.T.C. 2557 [3] 2004 TCC 438, [2004] 3 C.T.C. 2297 [4] 2009 TCC 587, [2010] 2 C.T.C. 2099 [5] 2010 FCA 287, 2010 DTC 5174(FCA) [6] 2004 TCC 619, [2005] 3 C.T.C. 2068 [7] 2010 TCC 142, [2010] 5 C.T.C. 2035 [8] 2011 ONCA 533, 335 DLR (4 th) 704 [9] 2012 TCC 325 ...

Oshawa Group Ltd., 2005 FCA 342 at paras. 8-9, 260 D.L.R. (4th) 193, leave to appeal refused, [2006] 1 S.C.R. xv; Venngo Inc. v. ... Ritvik Holdings Inc., 2005 SCC 65 at paras. 66-69, [2005] 3 S.C.R. 302. ... WOODS J.A.   DATED: December 2, 2019   APPEARANCES: David Allsebrook   For The Appellant   Tamara Ramsey   For The Respondents   SOLICITORS OF RECORD: LudlowLaw Toronto, Ontario   For The Appellant   Chitiz Pathak LLP Toronto, Ontario   For The Respondents     ...

NEAR J.A.   BETWEEN:     TUSK EXPLORATION LTD.     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard at Vancouver, British Columbia, on March 15, 2018. ... NEAR J.A.   BETWEEN:     TUSK EXPLORATION LTD.     Appellant     and     HER MAJESTY THE QUEEN     Respondent   REASONS FOR JUDGMENT WEBB J.A. [1]   This appeal arises as a result of the imposition of Part XII.6 tax under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ... The Queen, 2005 SCC 54, [2005] 2 S.C.R. 601, at para. 10: 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. ...

Signed at Ottawa, Canada, this 23 th day of January 2013   “Johanne D’Auray” D'Auray J.         ... (FORMERLY LANDEX INVESTMENTS), Appellant, and   HER MAJESTY THE QUEEN, Respondent.       ... Canada, [2005] 2 S.C.R. 601, that when the words of a provision are clear and unambiguous the words should be given a dominant role in the interpretative process, particularly when dealing with provisions that specify precisely what conditions must be satisfied to achieve a particular result. ...

Signed at Ottawa, Canada, this 21st day of March 2012.       "François Angers" Angers J.       ... The Queen, 2005 SCC 54, is to be used. That case predates the Supreme Court's decision in Copthorne Holdings Ltd. v. ...

Signed at Ottawa, Canada, this 13th day of October 2006.       “J.E. Hershfield” Hershfield J.         ... Sandia’s posted rent receipts were as follows:     1993 1994 1995 1996 1997 1998 1999   Posted Rent Receipts     $190,667 107,000 103,200 104,000 120,000 120,000 120,000 Unrealized Income/Economic Recovery (treated as loans) $152,000 87,000 57,000 93,000 92,000 89,000 99,000   After taking out amounts treated as loans from S & S, the reported rent was as follows:     1993 1994 1995 1996 1997 1998 1999                 Income Reported $38,667 33,333 31,200 23,000 28,000 31,000 21,611   [11]   The unrealized income/economic recovery amounts were added back to income under the reassessments so that the assessed amounts were as follows:     1993 1994 1995 1996 1997 1998 1999                 Additional Rent $152,000 87,000 57,000 93,000 92,000 89,000 99,000   [12]   1993 is the only year where amounts brought into income as rent exceeded the amount payable under the lease. ... The omissions were unintentional and Amended Judgments have been signed accordingly. [11] 2003 DTC 1065 (T.C.C.) [12] [2001] 3 C.T.C. 2256 (T.C.C.) [13] 2005 DTC 811 (T.C.C.) [14] 96 DTC 6588 [15] 84 DTC 6247 (F.C.T.D.) ...

Translation certified true on this 21 st day of August 2013.     François Brunet, Revisor         Citation: 2013 TCC 95 Date: 20130617 Docket: 2011-737(GST)G   BETWEEN: LES ENTREPRISES DRF INC., Appellant, and   THE MINISTER NATIONAL REVENUE, Respondent. ... Canada, 2005 FCA 425, at paragraph 20, the Federal Court of Appeal stated that "the burden of proof put on the taxpayer is not to be lightly, capriciously or casually shifted... ...   [65]         The appeal is dismissed with costs.     Signed at Ottawa, Canada, this 17th day of June 2013.   ...

La Reine, 2007 TCC 628 (Informal Procedure)       Docket: 2003-4101(IT)I BETWEEN: LOUISETTE GROS-LOUIS, Appellant, and   HER MAJESTY THE QUEEN, Respon dent.   ... In 2004 and in 2005, the Caisse had liquid assets and investments in the amount of $34.9 million and $39 million in each of these years ...     [37]     The appeal is dismissed.     Signed at Ottawa, Canada, this 6th day of December 2007.       ...