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The Court went on, at paragraph 33, to state that [33]      … in a case where consideration has to be paid, the recipient is the one who, ultimately, under an agreement for a supply [according to paragraph (a)] or otherwise [according to paragraph (b)], is liable to pay that consideration. [60]         I made similar observations in the decision in Bondfield Construction Co. (1983) Ltd. v The Queen, 2005 TCC   78, [2005] TCJ No. 239: [121]    Under subsection 169(1), the person entitled to claim the ITC is the person to whom the supply is made; and under subsection 123(1) that person is deemed to be the “recipient”. ... Although this tax was collected in error, the Respondent argued that the Appellant is still obligated to remit it even though it has been collected in error (800537 Ontario Inc. v Canada, 2005 FCA 333, [2005] FCJ No. 1732). ... Yaskowich   Firm: Felesky Flynn LLP For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Both parties’ counsel’s arguments at the hearing were supplemented with later written submissions. [2]              The trust was established by deed of trust creating the Fiducie Famille Mathio Pellerin in January 2005 (the “trust”) for the benefit of, among others, Mathio Pellerin, his children and his grandchildren, from their birth or their adoption, as well as any legal person controlled by Mathio Pellerin. ... The FIDUCIE FAMILLE MATHIO PELLERIN (the Trust) set up on January 15, 2005 (Al-1) is a “personal trust” [3] as defined in the Income Tax Act, R.S.C. 1985, c. 1 (5th Suppl.) ... The “ the aggregate of all amounts ” in issue within the meaning of section 2.1 of the Tax Court of Canada Act is •          $12,211 for the 2008 taxation year; •          $1,838 for the 2009 taxation year; and •          $991 for the 2010 taxation year. ...

There was no evidence of the amount of professional fees for 2002 however the Appellant produced a receipt dated August 9, 2005 indicating that the fees were $214 (including GST) in that year. This would mean that fees increased from $160.50 in 2001 to $214 in 2005 or approximately, on average, $13.37 / year. ... Webb DATE OF JUDGMENT:                     April 18, 2007 APPEARANCES: For the Appellant: The Appellant himself Counsel for the Respondent: Andrew Miller COUNSEL OF RECORD:        For the Appellant:                    Name:                                                 Firm:        For the Respondent:                     John H. ...

Leonelli-Contino, 2005 SCC 63 (CanLII); [2005] 3 S.C.R. 217 [Contino], Bastarache J. clearly articulated that the underlining principle relating to child support in the Divorce Act, R.S.C. 1985, c. 3 (2nd Supp.) ... Miller DATE OF JUDGMENT: July 6, 2017   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Amit Ummat   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]           CRA publication entitled “Shared Custody and the Amount for an Eligible Dependant”. [2]           [1990] 1 SCR. [3]           2014 TCC 263. [4]           2013 FCA 69. ...

GLEASON J.A.   BETWEEN:     ONENERGY INC.     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard at Toronto, Ontario, on October 16, 2017. ... GLEASON J.A.   BETWEEN:     ONENERGY INC.     Appellant     and     HER MAJESTY THE QUEEN     Respondent   REASONS FOR JUDGMENT WEBB J.A. [1]   This is an appeal from a determination made by Justice C. ... The Queen, 2005 SCC 54, [2005] 2 S.C.R. 601, at paragraph 10). Paragraph 141.1(3)(a) of the Act is broadly worded and in addressing the words “in connection with” the Tax Court judge stated: 21   Keep in mind, I am still just looking at this from a textual perspective, which, on its face, given jurisprudence's acceptance of a relatively broad view of the term, would appear to link, albeit tenuously, the legal services to the commercial activity of the Spectrum Sale, thus giving it the requisite commercial nature. ...

During the relevant period it had approximately 40 employees in two divisions: the plumbing division and the heating and ventilation division. [5]              The Appellant was the controlling mind and sole director of each of the Three Companies. [6]              Sometime in August 2005, TEC entered into a contract with an entity called Happy Valley Resort to design and build mechanical systems for a condominium project in Kelowna, British Columbia (the “Happy Valley Contract”). ... Pentney Deputy Attorney General of Canada Ottawa, Canada   [1]           Exhibit A-1, page 16; Transcript, March 25, 2014, pages 76 to 86, testimony of Jeffrey Maxwell. [2]           Buckingham v. Canada, 2011 FCA 142, [2013] 1 F.C.R. 86, 2011 DTC 5078 (“ Buckingham ”), at paragraph 47. [3]           Exhibit R-3. [4]           Exhibit R-4. [5]           Reply in 2011-2687(IT)G at paragraph 4 and Reply in 2011-2688(GST)G at paragraph 6. [6]           Exhibit R-14. [7]           Exhibit R-12. [8]           Exhibit R-1 and Reply in 2011-2668(IT)G, at paragraph 4. [9]           Exhibit R-10. [10]          Buckingham, supra, at paragraph 37. [11]          Transcript, March 25, 2014, pages 101 and 102, testimony of Jeffrey Maxwell. [12]          Ibid., pages 110 and 111. [13]          Ibid., page 102. [14]          Ibid., page 124. [15]          Ibid. [16]          Ibid., page 26. [17]          Ibid. [18]          Buckingham, supra, at paragraph 40. [19]          Ibid., at paragraph 49. ...

The Queen, 2004 TCC 315, 2005 G.S.T.C. 75. In my view, this decision is distinguishable, since my colleague Justice Tardif found that all of the members of the group either occupied the residence at the time the rebate application was made or intended to occupy the residence. [46]         Unfortunately, this is not the fact situation before me. ... D'Arcy DATE OF JUDGMENT: January 16, 2015   APPEARANCES:   Counsel for the Appellant: Yan Wang Counsel for the Respondent: Tony Cheung   COUNSEL OF RECORD: For the Appellant: Name: Yan Wang Firm: Hodder Barristers Toronto, Ontario   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada   [1]           Subsections 165(1) and 165(3). [2]           Subsections 165(1), (2) and (3). [3]           Subsections 165(1) and 165(2), section 1 of Part IV of Schedule IX, and Schedule VIII. ...

He said his work at Hidi involved some weekend and evening work to meet deadlines; −        he submitted time sheets to Hidi and every two weeks he submitted invoices for hours engaged at an agreed hourly rate: −        projects were assigned by a project manager with an hourly budget. ... He remitted the GST as required; −        there were no EI or CCP or income tax withholdings; he received no benefits or holiday pay; −        Hidi issued T4A's for his gross fees each year including GST, which he added to his business statements netting out the GST on the statements; −        after being terminated in 2003, he was denied EI benefits. [8]      The Respondent called Hidi's accounting manager to give evidence. ... Canada, [2005] T.C.J. No.164 (T.C.C.); Royal Winnipeg Ballet v. Canada, [2006] F.C.J. ...

Schedule A thereto reads: FAMILY YEAR EMPLOYMENT ALLOWANCE OTHER OTHER 1987 $45,607.38 $501.60 nil 1988 $45,545.66 $492.00 $ 48.06 1989 $50,137.00 nil nil 1990 $49,672.81 $504.00 $ 4.05 1991 $54,526.54 $584.40 $714.57 Her evidence also in no way challenged or disputed the facts assumed by the Minister when he made her assessment, which were reproduced in paragraph 5 of the Minister’s reply to her notice of appeal. ... Schedule A thereto reads: FAMILY UNEMPLOYMENT YEAR EMPLOYMENT ALLOWANCE INSURANCE OTHER 1987 $ 3,821.60 $652.80 nil ($782.47) 1988 $ 8,781.82 NIL NIL $ 1.99 1989 $11,195.19 $494.40 $3,935.00 $370.26 1990 $ 1,638.00 NIL $6,299.00 NIL 1991 $15,847.72 NIL NIL $ 21.29 When Linda was asked the question: “What was your 1992 loss?” ... M.N.R., [1974] C.T.C. 2003, 74 D.T.C. 1035 (T.R.B.), said at page 2005 (D.T.C. 1036-37): There is no doubt whatsoever in my mind that the appellant is now engaged in the business of farming and can entertain a reasonable expectation of making a profit from his operation, but that of course is not the issue of this appeal. ...

Lee’s application for leave to appeal the General Division’s decision. [11]   The Appeal Division focused on two issues: (1) whether there was an arguable case that the General Division committed an error of law by concluding it had no power to remedy administrative errors; and (2) whether the General Division overlooked or misconstrued relevant evidence. [12]   The Appeal Division noted that it had to determine whether the General Division committed one or more errors as set out in subsection 58(1) of the Department of Employment and Social Development Act, SC 2005, c 34 [DESDA]. ... IV.   Conclusion [26]   In short, the Appeal Division’s reasons for refusing Mr. ... DATED: SEPTEMBER 19, 2019   APPEARANCES: Donald Lee   For The Applicant (ON HIS OWN BEHALF)   Marcus Dirnberger   For The Respondent   SOLICITORS OF RECORD: Attorney General of Canada Ottawa, Ontario   For The Respondent     ...