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There were 26 documents included in Document 108.   Document Decision #441 Agenda for meeting between Finance and CRA, August 31, 2005 and email from Ryan Hall to Lawrence Purdy Agenda is not redacted. ... In addition it contains taxpayer information which is protected by s.241. #350 Email dated September 8, 2005 from Marc Vanasse, CRA to Brian Ernewein, Finance with an attachment. There were no redactions to this document. #128 Chain of emails dated December 15, 2005 from Marc Symes, CRA to Ryan Hall, Finance with attachments The redacted portions at #128 do not have to be produced for the same reason given for #441. ...

Examples of life‑sustaining therapy: •          Chest physiotherapy to facilitate breathing •          Kidney dialysis to filter blood •          Insulin therapy to treat Type 1 diabetes in a child who cannot independently adjust the insulin dosage (for 2005 and later years) The form T2201 also defines “markedly restricted” and “inordinate amount of time” as follows: Markedly restricted — means that all or substantially all of the time (at least 90% of the time), and even with therapy (other than therapy to support a vital function) and the use of appropriate devices and medication, either: •          your patient is unable to perform one or more of the basic activities of daily living (see above); or •          it takes your patient an inordinate amount of time (defined in the introduction of this form) to perform one or more of the basic activities of daily living.. . . ... “Patrick Boyle” Boyle J.   CITATION: 2018 TCC 42     COURT FILE NO.: 2016-2556(IT)I     STYLE OF CAUSE: SANDRA HUGHES v. ... Ian Wiebe   COUNSEL OF RECORD:       For the Appellant:       Firm:       For the Respondent: Nathalie G. ...

The appellant is entitled to costs.               Signed at Ottawa, Canada this 23rd day of May 2007.                                                    ... The Queen, [2005] G.S.T.C. 110 (T.C.C.); and Bokrika Inc. v. The Queen, [2006] G.S.T.C. 78 (T.C.C ... The appeal is allowed, with costs.       Signed at Ottawa, Canada this 23rd day of May 2007.     ...

Signed at Ottawa, Canada, this 10th day of June 2009.     “Diane Campbell” Campbell J.         ... In 2005, the CRA retained an outside valuator, Marco Fournier of Les Consultants Forestiers M.S. ... At that time, counsel for the Appellant was advised by the Appeals Officer that the valuation would be completed by November 2005. ...

Signed at Ottawa, Canada, this 2nd day of December, 2022.   “K. Lyons” Lyons J. ... Canada, [2005] T.C.J. No. 614, 2005 TCC 761; Hardtke v. Canada, [2005] T.C.J. ... See also, Chad v The Queen, 2021 TCC 45 [Chad] [55] Respondent’s Written Submissions, paragraph 48. [56] 2005 FCA 159 [Telus]. ...

Daniela Possamai, Translator       Citation: 2007TCC563 Date: 20071114 Docket: 2006-2496(EI) BETWEEN:   MARIO GAUTHIER, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent, and   LIETTE CÔTÉ, Intervener.   ... The Minister determined that the Intervener (the worker) was not employed under a contract of service and that, therefore, she was not in insurable employment within the meaning of paragraph 5(1)(a) of the Act when she was employed with the Appellant, who operated an excavation and snow removal business under the names Excavation et Déneigement MG Enr. and Rénovation et Entretien SC, during the periods from August 26, 2002, to            June 6, 2003, from June 30, 2003, to March 12, 2004, from April 5, 2004, to January 7, 2005, and from February 7, 2005, to January 20,  2006 (the relevant periods). ... Boyer, filed as Exhibit I‑5, also indicate that   (i)      the worker received Employment Insurance benefits for as long as possible for each of the years in issue, that is for 24 weeks in 2003, for 26 weeks in 2004 and for 20 weeks in 2005;   (ii)      the worker claimed benefits as soon as she accumulated the number of hours necessary to qualify for Employment Insurance benefits;   (iii)     she always worked 40 hours during her work weeks;   (iv)     the Appellant’s business was not seasonal ...

[OFFICIAL ENGLISH TRANSLATION]       REASONS FOR JUDGMENT   Archambault J ... M.N.R., [2005] TCJ No. 16 (QL), 2005 TCC 36. I explain as follows in paragraph 35:   [35]      The role vested in this Court is to carry out a two-stage analysis.  ...     [23]          For these reasons, the appeals of LAJ are dismissed.     ...

Webb” Webb J.         Citation: 2008TCC239 Date: 20080515 Docket: 2007-3967(GST)I BETWEEN:   MICHAEL SOMERS, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       ...   [10]     The assessed value of the property for municipal tax purposes as of February 1, 2005 was initially determined to be $358,000. ... The Queen, 2004 D.T.C. 3227, aff'd 2005 D.T.C. 5223. However, where the cost of a piece of property is indicative of fmv it is in cases where the cost is the price at which a property is bought in an arm's length sale. ...

For the respondent: — The amount of $100,000* was set up as a liability and deducted as an expense in order to reduce the total amount of taxes payable by the appellant: (*The amount at issue in the appeal, the total was $110,000) — There was no contract or agreement between the appellant and the persons to whom the alleged bonus was owing and a bonus would be paid; — There was no contract of employment between the appellant and any person who was within the management category requiring the payment of the stated bonus; — With respect to the bonuses no expense was made or incurred for the purpose of gaining and producing income for the businesses; — The claim of the bonus expense, if it has been found to have been made or incurred unduly or artificially reduces the income of the appellant; — The appellant did not intend to create a legal obligation to pay the bonuses; — The claim of bonus payable as an expense was in effect a reserve which is not permitted by the Income Tax Act. ... However, there were certain critical factors introduced: — the financial statements for previous years indicated a similar process of “bonus” accrual had regularly taken place; the 1976 financial statements showed in part: Revenue $1,049,301.20 Expenses 794,376.62 Profit before undernoted $ 254,924.58 Add — Gain on sale of fixed assets 150,936.00 $ 405,860.58 Less — Management bonus 110,000.00 $ 295,860.58 — Mr Staley noted that it was the business policy of his firm that clients reduce corporate profits by the utilization of such accrued management bonuses where and when it was advantageous, so that such an accrual would bring the net taxable profit from active business below the small business limit. ... The basic conditions outlined in McClain Industries of Canada, Inc v Her Majesty the Queen, [1978] CTC 511; 78 DTC 6356; and in G W Dorman Pulp Chip Company Ltd v MNR, [1981] CTC 2005; 81 DTC 18, would appear to be fulfilled. ...

He quoted the following passage from Bulk Transfer Systems Inc v The Queen, 2005 FCA 94 at paragraph 33: The balance in the RDTOH account at the end of a particular year is reduced in the following year by the amount of dividend refunds to which the corporation has become entitled as a result of the payment of taxable dividends to its shareholders. [17]         Counsel further argued that there are two conditions to the entitlement of a dividend refund in subsection 129(1). ... According to his conclusion, if a corporation failed to file its tax return within three years after its year end, it was not entitled to receive a “ refund of an amount” and therefore its “dividend refund” was nil. [24]         It is widely recognized that statutory provisions must be interpreted with regard to their text, context and purpose harmoniously with the scheme and object of the Act as a whole: Canada Trustco Mortgage Co v The Queen, 2005 SCC 54 at paragraph 10. ... The Minister subtracted the respective amount in computing the appellant’s refundable dividend tax on hand (colloquially referred to as RDTOH) at the end of taxation year for 2007, 2008, 2009, 2010 and 2011 (as further detailed in Schedule “A” attached):   Taxation Year for Computation of RDTOH at end of Taxation Year – s.129(3) Amount of the Corporation’s Dividend Refund for its Preceding Taxation Year – s. 129(3)(d) Preceding Taxation Year   2007   $0   2006   2008   $24,600   2007   2009   $789   2008   2010   $0   2009   2011   $1,545   2010     Further to paragraph 16 above, additional details respecting the appellant’s computation of the “dividend refund” for the year claimed by the appellant in respect of the 2010 and 2011 taxation years is set out in Schedule “B” attached.   ...