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This is also supported by the preamble in paragraph 115(2)(c.1) applicable to both sub-paragraphs where it stated “irrespective of … the form or legal effect of the contract …”. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     [1] Canada Trustco Mortgage Co. v. ... HMQ, 2005 TCC 812 at para 101. [14] Supra note 12 at paragraph 21. [15] Khabibulin v. ...

Buckingham, 2011 FCA 142 (“ Buckingham ”) and Balthazard v. Canada, 2011 FCA 331 (“ Balthazard ”). In Balthazard, Mainville J.A. summarized the matter as follows (para. 32): 32.   (…) a.   ... Wise, 2005 SCC 68, (2004) 3 S.C.R. 461 (“ Peoples ”), was a corporate law case in which the Supreme Court of Canada dealt with a director’s duty of loyalty and duty of care under paragraphs 122(1)(a) and (b) of the Canada Business Corporations Act, R.S.C. 1985, c. ...

the Respondent’s motion to quash under paragraph 53(3)(c) of the Tax Court of Canada Rules (General Procedure) (the “ Rules ”) is dismissed; 2.      ... All property passing to the Trustee under the bankrupt estate is subject to the Trustee’s sole right, subject to section 38 of the BIA, to initiate an appeal and the bankrupt retains no residual rights: 4028490 Canada Inc. v Canada, [2005] TCJ No. 95(QL). ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Malik began looking into financing. [6]              Mr. Malik and his wife had made poor financial choices in 2005 that resulted in each of them declaring personal bankruptcy in 2006. ... Graham DATE OF JUDGMENT: April 15, 2015   APPEARANCES:   Agent for the Appellant: Stephen Ji Amy Sujae Lee Counsel for the Respondent: Adam Gotfried   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           I do not have evidence of the actual closing date. ...

She worked as an assistant pharmacist from 2003 to 2005. She studied at the Dubai Pharmacy College from 2007 to 2010. [6]                On February 3, 2016, the applicant was admitted to the “Health, Assistance and Nursing care” diplôme d’études professionnelles (DEP) program at the Competency Development Centre Vimont (Laval) operated by the Sir Wilfrid Laurier School Board. ... V.                 Issues [13]            The issues raised in this case are: 1.       ... DATED: October 21, 2016   APPEARANCES: Jacques Beauchemin   For the Applicant   Suzon Létourneau   For the Respondent   SOLICITORS OF RECORD: Beauchemin Brisson Avocats Montréal, Quebec   For the Applicant   William F. ...

The Appellant’s appeals of the reassessments of her 2005, 2006, 2007, 2010 and 2011 tax years are hereby quashed. ... The Queen (“ Mariano ”), Justice Pizzitelli dismissed their appeals. [1] [9] The Minister accordingly confirmed the reassessments of the taxpayers who had signed Agreements to be Bound. ... The Appellant’s appeals of the reassessments of her 2005, 2006, 2007, 2010 and 2011 tax years are quashed. ...

The shareholders at that time were the Appellant, George Sofos and Chris Kambouris. 3.          1174429 Ontario Inc. was at all material times a Canadian Controlled Private Corporation ("CCPC") as defined by the Income Tax Act. 4.          1174429 Ontario Inc. was engaged in active business from the date of its incorporation until sometime in the latter part of 2005 when it ceased to carry on business. 5.          ... (ii)       The factors a creditor should take into account are: [3]             "1.         ... McNevin                             Firm:                      Ducharme Fox, LLP        For the Respondent:                     John H. ...

CITATION:                                        2007TCC31 COURT FILE NO.:                             2006-2362(GST)I and 2006-2723(GST)I STYLE OF CAUSE:                           Leslie E. ... Miller DATE OF JUDGMENT:                     January 19, 2007 APPEARANCES: For the Appellants: The Appellants themselves Counsel for the Respondent: Tyler Lord COUNSEL OF RECORD:        For the Appellant:                           Name:                                                   Firm:        For the Respondent:                     John H. Sims, Q.C.                                                           Deputy Attorney General of Canada                                                           Ottawa, Canada [1]           2004 DTC 2049. [2]           2000 DTC 6593. [3]           2004 SCC 68. [4]           97 DTC 5407. ...

Translation certified true On this 23 rd day of June 2017     François Brunet, Reviser   Citation: 2016 TCC 101 Date: 20160502 Docket: 2010-3810(IT)G BETWEEN: ANNIE SAUVIGNON, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... The Queen, 2005 DTC 377, that a loan did not constitute a transfer of property within the meaning of section 160 of the ITA. [20]         However, in my opinion, the appellant has failed to show, on a balance of probabilities, that Mr.  ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Paragraph 8 of the Reply, reads: 8.          In so assessing and confirming the Appellant, the Minister relied on the following assumptions of fact:             a)      The Appellant is a financial institution;             b)     The Appellant contracted with various collection agencies in order to collect payment by its debtors who were in default;             c)      The task of the collection agencies was to recover and deposit the amounts in a trust account, the beneficiary of which was the Appellant;             d)     Within the parameters established by the Appellant these collection agencies could accept a lesser amount of the debt as a final settlement;             e)      In exchange for these services, the collection agencies receive a percentage of the amounts thus recovered. ... Judgment in that appeal has been reserved. [7]      Mr. Ezri's arguments on this point are as follows: There are three reasons why these cases should be heard in the usual manner rather than under Rule 58: 1)       The issue raised by this motion was the subject of a full trial on November 30, 2005 involving one of the same appellants. ... The collection services rendered by the collection agencies constitute financial services because they are described in any of the following paragraphs of the definition of "financial service" found in subsection 123(1) of the ETA:          (a)      the...receipt or transfer of money, whether effected by the exchange of currency, by crediting or debiting accounts or otherwise [...];          (d)      the...variation, transfer of ownership or repayment of a financial instrument (i.e., the debt securities giving rise to the amounts owing) [...];          (f)       the payment or receipt of money as...interest, principal...or any similar payment or receipt of money in respect of a financial instrument (i.e., the debt securities giving rise to the amounts owing) [...];          (l)       the agreeing to provide, or the arranging for, a service referred to in any of (the above) paragraphs [...]. [11]     Counsel referred to certain decisions of this court in which applications under section 58 of the Rules were considered: Webster et al. v. ...