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FCTD
Anderton v. Canada (Attorney General), 2021 FC 788
Anderton owes amounts related to the 1999-2003 and 2005 taxation years, and Mrs. ... Anderton. JUDGMENT IN T-1028-20 AND T-1029-20 THIS COURT’S JUDGMENT is that: These applications for judicial review are dismissed. ... Southcott” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1028-20 T-1029-20 STYLE OF CAUSE: JOEL ANDERTON V THE ATTORNEY GENERAL OF CANADA AND BETWEEN BERNADETTE ANDERTON V. ...
TCC
McKenzie v. The Queen, 2011 DTC 1216 [at at 1274], 2011 TCC 289
Signed at Ottawa, Canada, this 9 th day of June 2011. "Patrick Boyle" Boyle J. ... APPENDIX Court File No. 2009-2898(IT)G TAX COURT OF CANADA BETWEEN: SHIRLEY PATRICIA MCKENZIE Appellant, - and- HER MAJESTY THE QUEEN, Respondent. ... The Action was settled by a settlement agreement made in December of 2005 but misdated December 16, 2006. ...
TCC
Price v. The Queen, 2008 TCC 153 (Informal Procedure)
« François Angers » Angers J. Citation: 2008TCC153 Date: 20080411 Dockets: 2006-1590(IT)I, 2006-1591(GST)I, 2006-1425(GST)I BETWEEN: LESLIE PRICE, LILLIAN JENKINS, Appellants, and HER MAJESTY THE QUEEN, Respondent. ... According to the extracts from New Brunswick ’s Corporate Affairs Registry Database produced at trial, both appellants were directors of C‑Shells from its previous status change on October 31, 2000 to its dissolution in 2005, but there is nothing indicating when the incorporators officially ceased to be directors of C‑Shells ... [38] The goods and services tax appeal (2006-1591(GST) is dismissed. ...
TCC
Vegh v. The Queen, 2012 DTC 1131 [at at 3160], 2012 TCC 95 (Informal Procedure)
Signed at Ottawa, Canada, this 23rd day of March 2012. "Patrick Boyle" Boyle J. ... VEGH, Appellant, and HER MAJESTY THE QUEEN, Respondent. REASONS FOR JUDGMENT Boyle J ... [9] Mr. Vegh did not file Canadian tax returns after leaving Canada until 2006, when he filed for 2004 and 2005. ...
FCTD
Chapman v. Canada (Attorney General), 2019 FC 975
Chapman was found to have engaged in wrongdoing (gross mismanagement) under the Public Servants Disclosure Protection Act, SC 2005, c 46 [PSDPA] in failing to accommodate a disability (mental health issue) during a disciplinary process. ... DATED: JULY23, 2019 APPEARANCES: Michael Fisher FOR THE APPLICANT Spencer Shaw For The Respondent SOLICITORS OF RECORD: Raven, Cameron, Ballantyne & Yazbeck LLP/s.r.l. Barristers & Solicitors Ottawa, Ontario FOR THE APPLICANT Attorney General of Canada Department of Justice Canada Treasury Board Secretariat Legal Services Ottawa, Ontario For The Respondent ...
FCTD
Robinson v. Canada (National Revenue), 2018 FC 825
Canada (Customs and Revenue Agency), 2005 FCA 271, 2005 D.T.C. 5489, at para. 20. ... ROBINSON v MINISTER OF NATIONAL REVENUE PLACE OF HEARING: Calgary, Alberta DATE OF HEARING: december 5, 2017 JUDGMENT AND REASONS: ELLIOTT J. DATED: august 10, 2018 APPEARANCES: Rami Pandher For The Applicant Peter Basta For The Respondent SOLICITORS OF RECORD: Shea Nerland LLP Barristers and Solicitors Calgary, Alberta For The Applicant Attorney General of Canada Edmonton, Alberta For The Respondent ...
FCA
Canada v. Rio Tinto Alcan Inc., 2018 FCA 124
R., 2005 FCA 135, [2005] 2 C.T.C. 336 (Pantorama). The issue was the deductibility of the fees which Pantorama, a retailer doing business in shopping malls, paid to a firm of real estate consultants to assist it with leasing activities. ... RIO TINTO ALCAN INC. AND DOCKET: A-361-16 STYLE OF CAUSE: HER MAJESTY THE QUEEN v. ... RIO TINTO ALCAN INC. PLACE OF HEARING: Montréal, Quebec DATE OF HEARING: September 28, 2017 REASONS FOR JUDGMENT BY: PELLETIER J.A. ...
TCC
Suspended Power Lift Service Inc. v. The Queen, 2007 DTC 1505, 2007 TCC 519 (Informal Procedure)
The Queen, 2007 DTC 1505, 2007 TCC 519 (Informal Procedure) Docket: 2006-3247(CPP) BETWEEN: SUSPENDED POWER LIFT SERVICE INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... Webb” Webb, J. Citation: 2007TCC519 Date: 20070831 Docket: 2006-3238(IT)I BETWEEN: SUSPENDED POWER LIFT SERVICE INC., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... [12] In the case of Direct Care in-Home Health Services Inc. v. The Minister of National Revenue, 2005 TCC 173, Justice Hershfield made the following comments in relation to control: 11 Analysis of this factor involves a determination of who controls the work and how, when and where it is to be performed. ...
TCC
Bourgault v. The Queen, 2019 TCC 6
[OFFICIAL ENGLISH TRANSLATION] Appeal heard on June 11, 2018, in Sherbrooke, Quebec. ... Quatre Saisons’ financial statements as of April 15, 2002, as well as those for the fiscal years ending March 31, 2003, 2004 and 2005 were submitted as evidence. [16] According to Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Montminy v. The Queen, 2016 TCC 110, rev'd 2017 FCA 156
Canada, [2005] 2 S.C.R. 601, 2005 SCC 54 (CanLII), at paragraph 10, the Supreme Court of Canada sets out how the tax laws are to be interpreted:... ... Original Evaluation Report Fortin Gaignard Groupe Conseil Inc. 2001 2000 1999 Earnings before tax 705,000 1,497,000 1,581,000 Adjustment Amortization 98,000 97,000 93,000 Rental income- 6,000- 5,000-- 4,000 Rent-- 30,000-- 60,000 Interest income- 74,000-- 47,000-- 17,000 Loss on disposal of capital assets 1,000 5,000 Executive life insurance 4,000 4,000 4,000 Executive remuneration- 150,000- 130,000-- 60,000 Professional fees Adjusted professional fees Provision for future billing Bill to Hydro One Sales and marketing costs 225,000 Additional SR&ED expense SR&ED costs incurred Payroll increase - 200,000- 175,000 EBITDA 803,000 1,191,000 1,362,000 Low High Representative cash flows used 950,000 1,100,000 Int. on additional borrowing capacity- 4,000- 4,000 - 20,000- 26,000 Income tax at low rate (22%)- 44,000- 44,000 Income tax at high rate (31%)- 225,060- 269,700 Capital reinvestment- 80,000- 105,000 Representative cash flow 575,000 650,000 Capitalization rate (multiple) 4.75 4.50 Present value of representative cash flows 2,731,250 2,925,000 Present value of tax savings 60,000 60,000 Surplus assets 1,301,000 1,401,000 Value of development projects 500,000 600,000 FMV at April 30, 2011 4,592,250 4,986,000 Rounded median value Less: 26 Class C shares 832,000 832,000 12 Class D shares 244,200 244,200 17,400,000 Class A shares 3,516,050 3,909,800 FMV of 1 Class A share 0.202 0.225 CYBERTEC INC. ... Final Evaluation Tax Court of Canada 2001 2000 1999 Earnings before tax 705,000 1,497,000 1,581,000 Adjustment Amortization 99,000 97,000 93,000 Rental income Rent Interest income- 74,000- 47,000- 17,000 Loss on disposal of capital assets 1,000 5,000 Executive life insurance 4,000 4,000 4,000 Executive remuneration- 130,000- 40,000- 42,000 Professional fees Adjusted professional fees Provision for future billing Bill to Hydro One Sales and marketing costs 225,000 Additional SR&ED expense SR&ED costs incurred Payroll increase EBITDA 830,000 1,516,000 1,619,000 Low High Representative cash flows used 900,000 1,321,667 Int. on additional borrowing capacity- 2,750- 2,750 - 15,075- 19,575 Income tax at low rate (22%)- 44,000- 44,000 Income tax at high rate (31%)- 211,474- 340,796 Capital reinvestment- 80,000- 105,000 Representative cash flow 546,701 809,546 Capitalization rate (multiple) 4.80 4.60 Present value of representative cash flows 2,624,164 3,723,910 Present value of tax savings 45,000 45,000 Surplus assets 1,300,274 1,400,274 Value of development projects 500,000 600,000 FMV at April 30, 2011 4,469,438 5,769,184 Rounded median value Less: 26 Class C shares 832,000 832,000 12 Class D shares 244,200 244,200 17,400,000 Class A shares 3,393,238 4,692,984 FMV of 1 Class A share 0.195 0.270 CITATION: 2016 TCC 110 COURT FILE NO.: 2012-2142(IT)G, 2012-2144(IT)G, 2012-2145(IT)G, 2012-2146(IT)G, 2012-2147(IT)G, 2012-2148(IT)G and 2012-2150(IT)G STYLE OF CAUSE: MARIO MONTMINY v. ...