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The Queen, 2008 TCC 348         Docket: 2004-3932(GST)G BETWEEN:   J. ... April 2005 was his last one. He has been involved in the industry since 1982. ...   [34]    She identified Exhibit A-2 which is a letter written to her from the Rulings Department of Revenue Canada dated November 23, 2005. ...

The applicant's statement of claim is only a construct of assertions and allegations completely devoid of meaning and material facts to support an action in civil liability against the respondent.                                                               ... [See also Hung v Canada (Attorney General), 167 ACWS (3d) 435 at para 10 (available on QL); Shaw v Canada, 2010 FC 577 at para 8-9 (available on CanLII); Apotex Inc v Wellcome Foundation Ltd, 2003 FC 1229, at para 10, 241 FTR 174; Galarneau v Canada (Attorney General), 2005 FC 39 at para 18, 306 FTR 1]   [26]            Although in this case the applicant does not seek to introduce new evidence but rather proposes to amend his original statement of claim, I find that the principles established on the introduction of additional evidence are applicable. ... "Marie-Josée Bédard" Judge   Certified true translation Catherine Jones, Translator         FEDERAL COURT   SOLICITORS OF RECORD     DOCKET:                                        T-1935-12   STYLE OF CAUSE:                         MARC-ANTOINE GAGNÉ v HER MAJESTY IN RIGHT OF CANANDA   PLACE OF HEARING:                   Montréal, Quebec   DATE OF HEARING:                     January 28, 2013   REASONS FOR JUDGMENT:      BÉDARD J.   ...

Stewart and Nandini Somayaji Counsel for the Respondent: Mark Heseltine____________________________________________________________________   JUDGMENT             The appeals from the reassessments made under the Income Tax Act for the 2002, 2003, 2004 and 2005 taxation years and the appeal from the reassessment made under the Excise Tax Act, notice of which is dated July 31, 2006 in respect of the period of September 17, 2001 to September 16, 2003, are allowed, and the reassessments are referred back to the Minister of National Revenue for reconsideration and reassessment in accordance with the attached Reasons for Judgment.             ... Signed at Ottawa, Canada, this 12th day of March, 2010.     “E.P. Rossiter” Rossiter A.C.J.           ... Miller’s spouse, Barbara, accompanied him on many of the flights.       ...

When she received a further letter from CRA – dated May 6, 2011 – Tab 9 – she sent it to Gilmore. ... Between 1999 and 2005, she had not paid Grouter more than $100 as a fee and had not paid him or any previous preparer a percentage of a refund. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

“Many Questions (and a Few Possible Answers) About the Application of Rectification in Tax Law” (2005), 53 Can. ... London: Sweet & Maxwell, 2005. Snell’s Equity, 33rd ed., by John McGhee. ... Rather, it represents a straightforward application of the test for rectification: see Joel Nitikman, “Many Questions (and a Few Possible Answers) About the Application of Rectification in Tax Law” (2005), 53 Can. ...

INTRODUCTION PART ONE – MOTIONS TO COMPEL A tale of two motions to compel [1] Mrs. ... R [58] and stated that “[…] once an unqualified undertaking has been given, it is too late to refuse to provide an answer on grounds of relevance […]”. ... Canada, 2005 SCC 54 at para 44. [97] Birchcliff Energy Ltd. v. R, [2013] 3 C.T.C. 2169 at para 15; MP FCA, supra note 6 at para 28. [98] Superior Plus, supra note 29 at para 21. [99] MP FCA, supra note 6 at para 27. [100] Burlington TCC 2015, supra note 2 at para 54. [101] Coopers Park Real Estate Development Corporation v. ...

No evidence was offered to the effect that the fair market value of the goodwill should be of the same value at the beginning of 2005 and in September 30, 2006, namely 21 months after. ... McDonald Heidi Cullicutt   COUNSEL OF RECORD: For the Appellant: Name:   Firm:   For the Respondent: William   F.   Pentney Deputy Attorney General of Canada Ottawa, Canada       ...

“tax benefit” («  avantage fiscal  ») means a reduction, avoidance or deferral of tax or other amount payable under this Act …;    “tax consequences” («  attribut fiscal  ») to a person means the amount of … tax or other amount payable by … the person under this Act …. ... Canada, [2005] 2 S.C.R. 601, 2005 SCC 54. The principles relating to subsection 245(4) are summarized in paragraph 66 of that case. ... Sharlow” J.A.     “I agree             Eleanor R. Dawson J.A.”   “I agree             Johanne Trudel J.A.”     ...

MACTAVISH J.A.     BETWEEN:     VICTORIA Y. LOUIE     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard at Vancouver, British Columbia, on September 17, 2019. ... MACTAVISH J.A.     BETWEEN:     VICTORIA Y. LOUIE     Appellant     and     HER MAJESTY THE QUEEN     Respondent   REASONS FOR JUDGMENT DAWSON J.A. [1]   Tax Free Savings Accounts were designed to allow Canadians to increase their savings by earning tax-free investment income. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 the Supreme Court elaborated that the phrase “in contemplation” is not to be read “in the sense of actual knowledge but in the broader sense of ‘because of’ or ‘in relation to’ the series.” ...

The Queen, [2005] T.C.J.  No.  492, in which Justice Miller made the following comment at paragraph 33 of his decision: […] The Respondent did not raise subsection 200(2) and I simply raise it to illustrate to Mr.  ... The Queen, 2007 TCC 155, in which Justice Paris ruled in favour of the appellant regarding its claim for input tax credits, because, in his view, the claim met the regulatory requirements of section 169 of the ETA. [81]         In Westborough Place Inc., supra, the main issue was that on December 23, 2005, the Minister had closed the GST account of one of the appellant’s suppliers retroactive to June 30, 2001.  ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...