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Canada, 2005 SCC 54, [2005] 2 S.C.R. 601, at par. 10 (" Trustco Mortgage "): "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. ... " [53] In addition, the appellant submits that the preposition " pour " [for] (before the word " année " [year]) means " le moment où quelque chose doit se faire " [the time when something should happen] and is synonymous with " pendant " [during], " au cours de " [in the course of], " à l'égard de " [with respect to] and " quant à " [regarding]. [54] This Court agrees that the preposition " pour " means " à l'égard de " and " quant à " but it does not mean " pendant " or " au cours de. ... In fact, section 2 uses the words "in the year" (in French, " au cours de l'année ") and "for the year" (in French, " pour l'année "). ...

Justice O'Keefe     BETWEEN: AL MACKLAI Applicant and   CANADA REVENUE AGENCY Respondent   REASONS FOR JUDGMENT AND JUDGMENT   O’KEEFE J ... Canada (Customs and Revenue Agency), 2005 FC 173, [2005] F.C.J. No. 209 (QL). ... Kirvan Deputy Attorney General of Canada   FOR THE RESPONDENT       ...

Signed at Toronto, Ontario this 5 th day of October 2011.   “J. M. Woods” Woods J.         ... DOSHI, Appellant,   and   HER MAJESTY THE QUEEN, Respondent.     REASONS FOR ORDER     Woods J ... Leslie Morancie-Alexis at CRA’s International Tax Office in Toronto advised me on February 7, 2005 that the CRA had undertaken a review of the “Deemed Disposition” clause.  ...

Signed at Toronto, Ontario, this 2 nd day of November 2007.       " J. Woods " Woods J.       Citation: 2007TCC667 Date: 20071102 Docket: 2003-4552(IT)G   BETWEEN: DWAYNE HEPPNER, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... The Queen, 2005 D.T.C. 5397; Vankerk v. Canada, [2006] 3 C.T.C. 53; and The Queen v. ...

Specifically the Appellant said: ·         He met with Henry Thill; ·         He talked to Pasquale Cusano ("Cusano"); ·         He met with and talked to his brother, Stuart McPherson; ·         He met with and talked to the lawyer, James Comparelli ("Comparelli"); ·         He talked with his accountant, James McPherson; ·         He talked with John McCoach, the compliance officer at his employer, Yorkton Securities Ltd.; ·         He read and relied upon a legal opinion from Mr. ... R., [2005] 3 C.T.C. 2068.) QQ.    The Appellant also acknowledged that his brother, Stuart McPherson, was one of Mr. ... R., [2005] 3 C.T.C. 2068: The Appellant claimed to have donated $30,000.00 in 1997 to a charitable organization (A.B.L.E.). ...

The Queen, 2012 TCC 2           Docket: 2010-190(GST)G BETWEEN: MARTINE CHAMARD, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... Signed at Ottawa, Canada, this 9th day of January 2012.   “Paul Bédard” Bédard J.               ... Signed at Ottawa, Canada, this 9th day of January 2012.       “Paul Bédard” Bédard J.               ...

La Reine, 2007 TCC 119 (Informal Procedure)           Docket: 2006-2222(GST)I BETWEEN: ESTHER OUAHIDI, Appellant, and   HER MAJESTY THE QUEEN, Respondent. ... Indeed, upon reading the divorce settlement of November 14, 2006, between the Appellant and Ralph Abergel, which can be found at tab 6 of Exhibit A-1, it can be seen that   (a)      initially, the Appellant owned 50% of the issued and outstanding share capital of Estéral Inc., and the other 50% was held by Ralph Abergel;   (b)     initially, Appellant held 50% of the issued and outstanding share capital of Brouillard Lepage Inc., and the other 50% was held by Ralph Abergel;   (c)     on September 25, 2005, the Appellant and Ralph Abergel purchased, as equal co-owners, three vacant lots in the city of Longueuil known as lots 2588664, 2588665 and 2588666, in the Quebec cadastre, Chambly registration division (the Du Cerf properties);   (d)     the Appellant and Ralph Abergel also purchased a commercial building, located at 2220 Marie‑Victorin Boulevard in Longueuil, as equal co-owners;   (e)      on July 29, 1998, Ralph Abergel granted the Appellant a second hypothec on a commercial building located at 2174 Marie‑Victorin Boulevard in Longueuil ... Signed at Montréal, Quebec, this 22nd day of March 2007.       "Réal Favreau" Favreau J.     ...

Bissonnette;            q)        the Appellant did not use his mailing address in the Turks & Caicos Islands;            r)        the Appellant maintained an American cellular telephone from about 1997 through the 2000 taxation year;            s)        the Appellant was divorced throughout the taxation years and has two ex-wives;            t)         the Appellant has three sons, Guy, Stephane and Sacha whose years of birth are 1959, 1970 and 1974, respectively;            u)        the Appellant's three sons all live in the province of Quebec;            v)        the Appellant has two brothers and three sisters;            w)       four of the Appellant's five siblings are known to live in the province of Quebec;            x)        the Appellant was involved in a common law relationship with Paule Darveau during the taxation years in issue;            y)        the Appellant and Paule Darveau built a home together in St. ... The Queen, [2005] 4 C.T.C. 2260, in which the day of arrival is not counted, the total days spent by the appellant in Canada are significantly less. ... M.N.R., 2005 TCC 112, I quoted 1084767 Ontario Inc. (c.o.b. Celluland) v. ...

Translation certified true on this 6 th day of January 2005. Wendy Blagdon, Translator Citation: 2004TCC648 Date: 20040927 Docket: 2003-1279(EI) BETWEEN: 9041-6868 QUÉBEC INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... The following is an excerpt from this decision:             [...]             ... Translation certified true on this 6 th day of January 2005. Wendy Blagdon, Translator CITATION: 2004TCC648 COURT DOCKET NO: 2003-1729(EI) STYLE OF CAUSE: 9041-6868 Québec Inc. and M.N.R. ...

(i)      one of the arguments for reselling the immovables within a short time was that the rents were too low even though the appellant          (i)   has a lot of experience and could not have been unaware that the price of income properties is determined on the basis of rents;          (ii)  made a profit on each disposition of the income properties;          (iii) declared capital gains of $224,858 for the 2005 to 2009 taxation years; (j)            one of the appellant’s real estate agents was Paul-André Huard, an associate of the appellant’s spouse and of the Trust in a number of real estate transactions; (k)          Mr.  ... Signed at Ottawa, Canada, this 6th day of November 2014. “ Judge Favreau ” Favreau J. ... Pentney Deputy Attorney General of Canada Ottawa, Canada       ...