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Signed at Ottawa, Canada, this 19 th day of November, 2015.   “David Graham” Graham J.   ... Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           2008 FCA 89 at para 17 [2]             2013 TCC 60 [3]           2009 TCC 219 [4]           I also note in passing that the phrase “at the time of transfer” was not included in the third branch of the third test in Livingston. ... If he held all $75,000 in cash, she would receive no relief. [15]          2005 SCC 54 at para 47 [16]          Placer Dome Canada Ltd, v. ...

These false statements are of such a magnitude that, if allowed, would result in the refund of all taxes withheld or paid from 2005 through to 2009. ... The Queen, 2005 TCC 545; Panini v. Canada, 2006 FCA 224; Laplante v. The Queen, 2008 TCC 335; Gélinas v. ... Pentney Deputy Attorney General of Canada Ottawa, Canada   ...

The Queen, 2007 DTC 1593, 2007 TCC 548 (Informal Procedure)         Docket: 2006-2458(IT)I BETWEEN: HERVE L. ... Signed at Ottawa, Canada, this 28th day of September 2007.       "Lucie Lamarre" Lamarre J.         ...   [12]     In so deciding, I rely on the commentary by the OECD (Organisation for Economic Co-operation and Development) Committee on Fiscal Affairs on Article 4 (regarding the definition of resident) of the Model Tax Convention on Income and on Capital, in Model Tax Convention on Income and on Capital, condensed version, dated July 15, 2005, at page 80, paragraphs 11, 12 and 13 (see Respondent’s Book of Authorities Legislation, Tab B):   11. ...

Costs are awarded to the Appellant.   Signed at Ottawa, Canada, this 13th day of September 2010.       ... Pizzitelli” Pizzitelli J.       Citation: 2010 TCC 388 Date: 20100719 Docket: 2008-3556(IT)G   BETWEEN:   BARRINGTON LANE DEVELOPMENTS LIMITED, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... Canada, 2004 TCC 727, 2005 DTC 62, 170635 Canada Ltée v. Canada (Minister of National Revenue- M.N.R.), 93 DTC 1120 and Coastal Construction above. ...

Appellant and THE ATTORNEY GENERAL OF CANADA Respondent       REASONS FOR JUDGMENT STRATAS J.A.   ... However, as the appellants’ representative conceded in a letter dated June 2, 2005, that logic did not apply to the appellant Canwest Communications Corporation, which had U.S. investments administered by U.S. fund managers ... "David Stratas" J.A.         “I agree      Marc Noël J.A.”   ...

Signed at Ottawa, Ontario, this 24 th day of May 2019.   “B. Paris”   Paris J.       ... Signed at Ottawa, Ontario, this 24 th day of May 2019.   “B. Paris”     Paris J.     ... Canada, 2005 TCC 95 at paragraph 27. Also, this Court does not have the power to order the Minister to increase Ms. ...

The fact that another person like a dealer can make a request under that provision, it is only in a situation where the Province has decided that it does not want to bother to make a request and has requested to buy the product on a tax-exempt basis. [37]   Highlands argues the Minister’s interpretation of section 68.19 of the ETA is wrong and fails to satisfy the requirement that a provision be interpreted according to a textual, contextual, and purposive analysis (Canada Trustco Mortgage Co v Canada, 2005 SCC 54 at para 10; Canada v Cheema, 2018 FCA 45 at para 83). [38]   With regards to a textual analysis, Highlands argues that the Minister’s interpretation requires the Court to read in a condition for New Brunswick to have made a request for the dealer to reduce the Fuel’s purchase price by an amount equal to the Federal Excise Tax paid by Irving Oil.   ... Irving Oil Commercial G.P. paid Part III tax under the Excise Tax Act (the “ Act ”) (“ Federal Excise Tax ”) on the Fuel sold to Highlands. ... DATED: SEPTEMBER 11, 2019   APPEARANCES: Al-Nawaz Nanji Alan Kenigsberg   For The PLAINTIFF   André LeBlanc   For The DEFENDANT   SOLICITORS OF RECORD: Osler, Hoskin & Harcourt LLP Toronto, Ontario   For The PLAINTIFF   Attorney General of Canada Ottawa, Ontario   For The DEFENDANT     ...

Costs are awarded to the Appellant.             Signed at Ottawa, Canada, this 21st day of May, 2009.     ... Rossiter” Rossiter A.C.J.         Citation: 2009TCC272 Date: 20090521 Docket: 2006-1099(GST)G BETWEEN:   CITY OF CALGARY, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... Canada, 2005 TCC 809, [2006] T.C.J. No. 56 (T.C.C.) at para. 95. [39]          The question of whether, and in what circumstances, a person’s undertaking of an activity for which the person receives funding from a government body constitutes the making of a supply to that body for consideration was considered by the Federal Court of Appeal in Des Chênes (Commission scolaire) v. ...

" [16]          An investigation concerning Réjean Simard was begun on September 13, 1999, and he was dismissed six weeks later. ... He is on probation until November 2005. [17]          Réjean Simard said that that period was very difficult for him. ... I have no reason to believe it is much higher at the present time. [36]          The total amount of the reassessments seems very high, first, compared with the amount received in 1996, and second, in relation to the appellant's annual income. [37]          By letter dated March 18, 2002, counsel for the respondent sent me the particulars of the assessments, which read as follows: [TRANSLATION] Table- Particulars of Assessments 1990 Unjustified refund                                 $2,125.75                 Interest on this amount between                        $ 973.59                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 55.08    Interest on this amount between                        $ 25.24                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $1,062.87                 Interest on this amount between                        $1,407.01                                                                 April 30, 1991, and July 14, 2000 Total                                                        $3,243.70                                 Total interest                                         $2,405.84                                                                                 Grand total for 1990                                                            $5,649.54 1991 Unjustified refund                                 $2,166.74                 Interest on this amount between                        $ 992.40                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 56.14    Interest on this amount between                        $ 25.71                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $1,083.37                 Interest on this amount between                        $1,160.24                                                                 April 30, 1992, and July 14, 2000 Total                                                        $3,306.25                                 Total interest                                         $2,178.35                                                                                 Grand total for 1991                                                            $5,484.60 1992 Unjustified refund                                 $1,415.00                 Interest on this amount between                        $ 648.08                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 372.15 Interest on this amount between                        $ 170.45                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $ 707.50 Interest on this amount between                        $ 629.63                                                                 April 30, 1993, and July 14, 2000 Total                                                        $2,494.65                                 Total interest                                         $1,448.16                                                                                 Grand total for 1992                                                            $3,942.81 1993 Unjustified refund                                 $ 845.27 Interest on this amount between                        $ 387.15                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 148.82 Interest on this amount between                        $ 68.16                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $ 422.63 Interest on this amount between                        $ 318.36                                                                 April 30, 1994, and July 14, 2000 Total                                                        $1,416.72                                 Total interest                                         $ 773.67                                                                                 Grand total for 1993                                                            $2,190.39 1994 Unjustified refund                                 $ 780.53 Interest on this amount between                        $ 357.49                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 61.99    Interest on this amount between                        $ 28.37                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $ 390.26 Interest on this amount between                        $ 240.91                                                                 April 30, 1995, and July 14, 2000 Total                                                        $1,232.78                                 Total interest                                         $ 626.77                                                                                 Grand total for 1994                                                            $1,859.55 [38]          One notes that interest on the unjustified refunds was calculated from March 28, 1996, and that interest on the penalties was calculated from April 30 of each taxation year for which a refund was obtained. ...

Signed at Ottawa, Canada, this 6th day of June 2007.     “Lucie Lamarre” Lamarre J.           ... Counsel for the appellant was able to call instead Daniel Thibault, another collection agent with the CCRA, who was also involved in the appellant’s file in 2002 and has been again since mid‑September 2005, when Mr.  ... Signed at Ottawa, Canada, this 6th day of June 2007.         “Lucie Lamarre” Lamarre J.   ...